File Nos. 333-137411/811-08052

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM N-4

REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933	x
Pre-Effective Amendment No.	¨
Post-Effective Amendment No. 10	x
REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940	x
Amendment No. 74	x
(Check appropriate box or boxes.)

SYMETRA SEPARATE ACCOUNT C

(Exact Name of Registrant)

Symetra Life Insurance Company

(Name of Depositor)

777 108th Ave NE, Suite 1200, Bellevue, WA	98004
(Address of Depositor’s Principal Executive Offices)	(Zip Code)

Depositor’s Telephone Number, including Area Code (425) 256-8000

Name and Address of Agent for Service

Jacqueline M. Veneziani

777 108^th Ave NE, Suite 1200

Bellevue, Washington 98004

(425) 256-5026

Approximate date of Proposed Public Offering:

As Soon as Practicable after the effective date of this registration statement.

If appropriate, check the following:

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

It is proposed that this filing will become effective:

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

x On May 1, 2010, pursuant to paragraph (b) of Rule 485

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

¨ On                  pursuant to paragraph (a) of Rule 485

Title of Securities Being Registered:

Individual Flexible Premium Variable Annuity Contracts

Symetra Focus

Variable Annuity

issued by

SYMETRA SEPARATE

ACCOUNT C

and

SYMETRA LIFE

INSURANCE COMPANY

This prospectus describes an individual flexible premium deferred variable annuity contract, the Symetra Focus Variable Annuity Contract, and contains important information. Please read it before investing and keep it on file for future reference. This prospectus does not constitute an offering in any jurisdiction in which the contract may not lawfully be sold.

Investment in a variable annuity contract is subject to risks, including the possible loss of principal. The contracts are not deposits or obligations of, or guaranteed or endorsed by, any financial institution; and are not insured or guaranteed by the Federal Deposit Insurance Corporation, or any other government agency.

Neither the Securities Exchange Commission (“SEC”) nor any state securities commission has approved or disapproved of these securities or determined if this prospectus is accurate or complete. Any representation to the contrary is a criminal offense.

Dated: May 1, 2010

DWS INVESTMENTS VIT FUNDS

• DWS Small Cap Index VIP - Class A Shares

FIDELITY^® VARIABLE INSURANCE PRODUCTS

• Fidelity VIP Index 500 Portfolio - Initial Class

• Fidelity VIP Money Market Portfolio - Initial Class

IBBOTSON ETF ALLOCATION SERIES

• Ibbotson Aggressive Growth ETF Asset Allocation Portfolio - Class I

• Ibbotson Balanced ETF Asset Allocation Portfolio - Class I

• Ibbotson Conservative ETF Asset Allocation Portfolio - Class I

• Ibbotson Growth ETF Asset Allocation Portfolio - Class I

• Ibbotson Income and Growth ETF Asset Allocation Portfolio - Class I

VANGUARD^® VARIABLE INSURANCE FUND PORTFOLIOS

• Vanguard VIF - Balanced Portfolio

• Vanguard VIF - High Yield Bond Portfolio

• Vanguard VIF - International Portfolio

• Vanguard VIF - Mid-Cap Index Portfolio

• Vanguard VIF - REIT Index Portfolio

• Vanguard VIF - Total Bond Market Index Portfolio

• Vanguard VIF - Total Stock Market Index Portfolio

Symetra Focus Prospectus

You can allocate your Contract Value to Symetra Separate Account C (“Separate Account”), which invests in the Sub-accounts listed here. The Portfolio prospectuses for each of the Sub-accounts available through the Separate Account should be read in conjunction with this prospectus and, if not included with this prospectus, are available by request at no charge.

To learn more about the Symetra Focus Variable Annuity Contract, you can obtain a copy of the Statement of Additional Information (“SAI”) dated May 1, 2010. The SAI is incorporated by reference, has been filed with the SEC and is legally part of the prospectus. You may request a free copy of the SAI, a paper copy of this prospectus (if you have received it in an electronic format) or a prospectus for any of the underlying Portfolios, by calling us at 1-800-796-3872 or writing us at: PO Box 3882, Seattle, WA 98124-3882. The table of contents for the SAI can be found at the end of this prospectus. The SEC maintains a website at http://www.sec.gov that contains the SAI, material incorporated by reference, and other information regarding companies that file electronically.

Symetra Focus Prospectus

TABLE OF CONTENTS	Page
DEFINED TERMS	4
SUMMARY	5
FEE TABLE	8
EXAMPLES	10
1.    THE ANNUITY CONTRACT	12
Owner	12
Annuitant	12
Payee	12
Beneficiary	12
Assignment	12
2.    ANNUITY PAYMENTS (INCOME PHASE)	13
Payment Options	13
Annuity Options	13
Changing Sub-Accounts During The Income Phase	14
3.    PURCHASE	15
Purchase Payments	15
Allocation Of Purchase Payments	15
Accumulation Units	15
Right To Examine	16
4.    SUB-ACCOUNT OPTIONS	16
Sub-Account Options	16
Changes To The Sub-Accounts	18
Compensation We Receive From Portfolios	18
Voting Rights	18
Transfers	18
Transfer Transactions Available	19
Scheduled Transfers	19
Limits On Excessive Transfers And Market Timing Activity	19
5.    CHARGES AND EXPENSES	21
Insurance Charges	21
Optional Benefit Charges	22
Annual Administration Maintenance Charge	23
Surrender Charge	23
Free Withdrawal Amount	23
Waiver Of Surrender Charges Upon Healthcare Confinement	24
Withdrawal Charge	24
Transfer Charge	24
Premium Taxes	24
Income Or Other Taxes	24
Portfolio Expenses	24
6.    TAXES	24
Annuity Contracts In General	24
Death Benefits	24
Qualified Contracts	24
Tax Sheltered Annuities - 403(b) Contracts	26
Withdrawals From Roth Iras And Roth TSAs	26
Withdrawals For Investment Advisor Fees	26
Non-Qualified Contracts	27

Taxation Of Annuity Payments	27
Optional Benefit Riders - Non-Qualified Contracts	27
Effect Of Civil Unions And Domestic Partnerships	28
Exchanges	28
Diversification/Ownership	28
Tax Withholding	29
Federal Estate Taxes	29
Generation-Skipping Transfer Tax	29
Estate, Gift And Generation-Skipping Transfer Taxes In 2010	29
Annuity Purchases By Nonresident Aliens And Foreign Corporations	29
Foreign Tax Credits	29
Possible Tax Law Changes	29
7.    ACCESS TO YOUR MONEY	30
Partial Withdrawals	30
Surrendering Your Contract	30
Repetitive Withdrawals	30
Withdrawal Restrictions On TSA Contracts	31
Minimum Value Requirements	31
8.    OPTIONAL LIVING BENEFIT RIDERS	31
Guaranteed Long Life Benefit Rider (Patent Pending)	31
9.    DEATH BENEFIT AND OPTIONAL DEATH BENEFIT RIDER	33
Standard Death Benefit And Age Extension Rider	33
Payment Of Death Benefit	34
Death During The Accumulation Phase	35
Death During The Income Phase	35
10.  OTHER INFORMATION	36
Symetra Life	36
Separate Account	36
Changes to Separate Account	36
Distribution (Principal Underwriter)	36
Amendments To The Contract	37
Legal Proceedings	37
Right To Suspend Annuity Payments, Transfers, Or Withdrawals	37
Reduction Of Charges Or Additional Amounts Credited	37
Website Information	38
Financial Statements	38
TABLE OF CONTENTS OF THE STATEMENT OF ADDITIONAL INFORMATION	38
APPENDIX A:   CALCULATION OF SURRENDER AND WITHDRAWAL CHARGES	A-1
APPENDIX B:   ACCUMULATION UNIT VALUE HISTORY	B-1

Symetra Focus Prospectus

DEFINED TERMS

We have used simple, clear language as much as possible in this prospectus. However, by the very nature of the contracts certain technical words or terms are unavoidable. We have identified the following as some of these words or terms.

Accumulation Phase	The period between the date we allocate your first Purchase Payment and the Annuity Date. During this phase, you can invest money in your contract.
Accumulation Unit	A unit of measure we use to calculate the value in a Sub-account during the Accumulation Phase.
Annuitant	The natural person on whose life annuity payments for this contract are based. You are the Annuitant unless you designate someone else before the Annuity Date.
Annuity Date	The date annuity payments begin under an annuity option. This date must be before the maximum annuitization date specified in your contract.
Annuity Unit	A unit of measure we use to calculate the value of variable annuity payments during the Income Phase.
Beneficiary	The person or entity designated to receive any contract benefits upon the Owner’s death.
Business Day	Any day the New York Stock Exchange is open for regular trading.
Contract Date	The Business Day your initial Purchase Payment and all required information are received at Symetra Life. The Contract Date is identified on the contract data page.
Contract Value	The sum of the value of the Sub-accounts attributable to your contract.
Contract Year	A 12-month period starting on the Contract Date and each anniversary of that date.
Income Phase	The period beginning on the Annuity Date during which the Payee receives annuity payments.
Long Life Benefit Annuitant	The natural person on whose life the Long Life Benefit Payments are based. The Long Life Benefit Annuitant must be the same as the Owner, unless the contract is owned by a non-natural Owner, then the Long Life Benefit Annuitant must be the initial Annuitant.
Long Life Benefit Commencement Date	The date of the first Long Life Benefit Payment.
Long Life Benefit Payment	Monthly payments under the Guaranteed Long Life Benefit Rider that begin on the Long Life Benefit Commencement Date and continue as long as the Long Life Benefit Annuitant is alive.
NYSE	The New York Stock Exchange.
Net Investment Factor	A unit of measure we use in calculating the daily change in Accumulation Unit value for each Sub-account.
Owner	The person or legal entity entitled to exercise all rights and privileges under the contract. If there are joint Owners, the signatures of both Owners are needed to exercise rights under the contract. Any reference to Owner in this prospectus includes any joint Owner.
Payee	The person or persons designated by you to receive annuity payments and, if applicable, Long Life Benefit Payments under the contract.
Portfolios	The variable investment options in which the corresponding Sub-accounts invest.
Purchase Payment	An amount paid to Symetra Life for allocation under the contract, less any premium tax due at the time the payment is made.
Separate Account	Symetra Separate Account C, a segregated asset account established under Washington law.
Sub-account	A division of the Separate Account for which Accumulation Units and Annuity Units are separately maintained. Each Sub-account invests exclusively in a particular Portfolio. Your contract generally refers to “Portfolios” when referring to Sub-accounts.

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SUMMARY

Topics in this Summary correspond to sections in the prospectus which discuss them in more detail.

THE ANNUITY CONTRACT

The prospectus describes generally applicable provisions of the annuity contract. You should refer to your contract for any variations required by your state. The provisions of your contract control if inconsistent with any of the provisions in the prospectus.

The annuity contract (the “contract”) is an agreement between you, the Owner, and Symetra Life Insurance Company (“Symetra Life”, “we”, and “us”). It is designed to help you invest on a tax-deferred basis and meet long-term financial goals, such as retirement funding. The contract provides for a guaranteed income or a death benefit. You should not buy the contract if you are looking for a short-term investment or if you cannot accept the risk of getting back less money than you put in.

You may divide your money among the Sub-accounts available under the contract. Each Sub-account purchases the shares of a corresponding underlying Portfolio. The value of the Sub-accounts can fluctuate up or down based on the investment performance of the underlying investments. Your investment in the Sub-accounts is not guaranteed and you may lose money. Your choices for the various Sub-accounts are found in Section 4.

The contract has an Accumulation Phase and an Income Phase. During the Accumulation Phase, you invest money in your contract. Earnings accumulate on a tax-deferred basis and are treated as income when you make a withdrawal. Your earnings or losses are based on the investment performance of the Sub-accounts you selected. During the Income Phase, the Payee (you or someone you choose) will receive payments from your annuity.

The amount of money you are able to accumulate in your contract during the Accumulation Phase will determine the amount of payments during the Income Phase.

We offer other variable annuity contracts that have different features. However, these other contracts also have different charges that would affect your Sub-account performance and Contract Value. To obtain more information about these other contracts, contact our Home Office, at the contact information shown below under “Inquiries.”

ANNUITY PAYMENTS (INCOME PHASE)

You can select from one of five payment options: Life Annuity; Life Annuity with Guaranteed Period; Joint and Survivor Life Annuity; Joint and Survivor Life Annuity with Guaranteed Period; or Period Certain Annuity. This selection cannot be changed once you switch to the Income Phase. However, switching to the Income Phase does not affect the available

investment options under a variable annuity option. You can choose to have fixed or variable payments, or both, for all options other than period certain options. You may choose only fixed payments for Period Certain Annuity options. Any portion of annuity payments that you elect to have as variable payments will be based on investment in the Sub-accounts and will vary in amount depending on investment performance.

PURCHASE

You can buy the contract with $10,000. You can add $10,000 or more as often as you like during the Accumulation Phase. Any Purchase Payment in excess of $1 million dollars requires our prior approval.

INVESTMENT OPTIONS

Currently, this contract offers 15 Portfolios through the Sub-accounts of Separate Account C. Depending upon market conditions, you can make or lose money in any of these Sub-accounts. We reserve the right to add, combine, restrict or remove any Sub-account available as an investment option under your contract.

CHARGES AND EXPENSES

The contract has insurance features and investment features, and there are costs related to each.

We deduct insurance charges which equal a maximum of 1.35% annually of the average daily net assets of each Sub-account. The insurance charges are deducted daily and include: a mortality and expense risk charge which equals a maximum of 0.95% annually, and an asset related administration charge which equals a maximum of 0.40% annually.

Each Contract Year, we deduct an annual administration maintenance charge from your contract. The current charge is $40 and is waived if the value of your contract is $50,000 or more. The maximum charge is $50.

If you take more than 10% of your Contract Value out in a Contract Year, you may be assessed a surrender charge. The amount of this charge depends upon the length of time each Purchase Payment has been in your contract. The charge is based upon the amount withdrawn and starts at 7% from the date the Purchase Payment is made and declines until the eighth and later years of each Purchase Payment when there is no charge.

A separate withdrawal charge equal to $25 may apply to each withdrawal after the first in a Contract Year.

You can transfer between Sub-accounts up to 12 times per Contract Year free of a transfer charge. A transfer charge equal to the lesser of $10 or 2% of the amount being transferred may

Symetra Focus Prospectus

5

apply to each additional transfer. Your transfers may be limited, however, by market timing and excessive trading policies and procedures.

In a limited number of states there is a premium tax of up to 3.5%, depending upon the state. In this case, a premium tax charge for the payment of these taxes may be deducted.

There are also annual Portfolio expenses which vary depending upon the Portfolios you select. In 2009, these expenses ranged from 0.10% to 0.69%, after any fee waivers or expense reimbursements.

If you elect one or more of the optional benefit riders, we will deduct an additional charge. This charge will vary depending upon which optional benefit rider(s) you have elected. If you elect the Guaranteed Minimum Death Benefit – Age Extension (“GMDB – Age Extension”) rider, we will deduct, on an annual basis, an additional charge of 0.10% of the average daily net assets of each Sub-account.

If you elect the Guaranteed Long Life Benefit rider (“GLLB Rider”) we will deduct an additional charge for the first 10 Contract Years. Once elected, the GLLB Rider cannot be cancelled. The charge is expressed as a percentage of the first year Purchase Payments. The amount of the Long Life Benefit Payment that the GLLB Rider charge will purchase varies by the Long Life Benefit Annuitant’s age (and sex for non-qualified contracts), the deferral period, the amount of the first year Purchase Payments, and current interest rates and mortality tables. This charge is shown in your contract. It will never be greater than the maximum charge of 5% of the Purchase Payments made to your contract in the first Contract Year. If, at the end of the first Contract Year, first year Purchase Payments are not enough to keep the originally calculated charge at or below the maximum GLLB Rider charge, then you will need to invest additional Purchase Payments or your Long Life Benefit Payment will be reduced permanently.

The Fee Table following this Summary show the various expenses you will incur directly and indirectly by investing in the contract. There are situations where all or some of the Owner transaction expenses do not apply. See “Section 5 - Charges and Expenses” for a more detailed discussion.

TAXES

This description generally refers to the taxation of non- qualified contracts which are contracts issued outside of a qualified retirement plan. Generally, earnings and amounts equal to Purchase Payments are not taxed until you withdraw them from the contract. During the Accumulation Phase, if you take a withdrawal from a non-qualified contract you are taxed first on earnings. Earnings are taxed as ordinary income and do not qualify for lower rates applicable to long term capital gains and corporate dividends. Contracts issued in connection with certain retirement plans generally will result in taxable income even if there are no earnings in the contract. If you are younger than 59 ¹/2 when you withdraw money from the contract, you

may be charged a 10% penalty on the taxable amount. During the Income Phase, annuity payments are considered partly a return of your original investment and partly earnings, and are taxed in the year received.

ACCESS TO YOUR MONEY

You may withdraw money at any time during the Accumulation Phase unless you are restricted by requirements of a retirement plan. Each Contract Year, you can take up to 10% of the Contract Value without paying a surrender charge. Amounts in excess of 10% may be subject to a surrender charge. This charge varies based on the ages of your particular Purchase Payments. You may have to pay income taxes and tax penalties on any money you withdraw from the contract.

PERFORMANCE

The value of your contract will vary up or down depending upon the investment performance of the Sub-accounts you choose. Past performance is not a guarantee of future results.

DEATH BENEFIT AND OPTIONAL DEATH BENEFIT RIDER

If you die prior to the Income Phase, we will pay a death benefit as described in “Section 9 - Death Benefit and Optional Death Benefit Rider.” The standard death benefit is designed to protect your Contract Value from potentially poor investment performance and the impact that poor investment performance could have on your death benefit. The standard death benefit is provided through age 74 at no extra cost to you. If you are age 74 or younger at the time of death, the standard death benefit is equal to the greater of your Contract Value or 100% of your Purchase Payment minus applicable withdrawals and associated charges. If you are age 75 or older at the time of death, the standard death benefit is equal to your Contract Value. You may also elect an optional death benefit at the time you purchase your Contract. The GMDB-Age Extension rider is also designed to protect your Contract Value from poor investment performance after age 74 by allowing you to extend the death benefit protection until age 95. See “Section 9 - Death Benefit and Optional Death Benefit Rider” for more information.

OPTIONAL LIVING BENEFIT RIDERS

If approved in your state, you may purchase the GLLB Rider on the date you purchase the contract. The rider is available for non-qualified contracts and any Individual Retirement Annuity contract, as described below. The GLLB Rider guarantees that if the Long Life Benefit Annuitant is alive on the Long Life Benefit Commencement Date, we will make periodic payments as long as the Long Life Benefit Annuitant is living. The Long Life Benefit Payments are separate from and in addition to any annuity payments if you choose to annuitize your contract. See “Section 8 - Optional Living Benefit Riders” for more information. The GLLB Rider is available only for contracts owned by one Owner. If the contract is owned by a non-natural

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Owner, only one Long Life Benefit Annuitant may be named, and the Long Life Benefit Annuitant must be the initial Annuitant.

OTHER INFORMATION

Right to Examine.  If you cancel the contract within 10 days after receiving it (or any longer period that is required in your state), we will send your money back without assessing a surrender charge or any other charges. You will receive:

• whatever your contract is worth on the day we receive your request which may be more or less than your original Purchase Payment;

• a return of Purchase Payments; or

• the greater of the two, depending on state law requirements or if your contract is an Individual Retirement Annuity (“IRA”), ROTH IRA, SIMPLE IRA or SEP IRA.

Transactions.  Under the following strategies, you can initiate transfers or withdrawals as desired or schedule them in advance. These are available at no additional charge.

• Dollar Cost Averaging: You may elect to automatically transfer a set amount from any Sub-account to any of the other Sub-accounts monthly or quarterly. This feature attempts to achieve a lower average cost per unit over time.

• Appreciation Sweep: If your balance in the Fidelity VIP Money Market Portfolio is at least $10,000, you may elect to have interest from earnings (if any) from the Fidelity VIP Money Market Portfolio automatically swept monthly, quarterly, semi-annually, or annually into any other Sub-account of your choice.

• Sub-account Rebalancing: If your Contract Value equals or exceeds $10,000, you may elect to have each Sub-account rebalanced quarterly, semiannually, or annually to maintain your specified allocation percentages.

• Repetitive Withdrawals: You may elect to receive monthly, quarterly, or annual checks during the Accumulation Phase. Any money you receive may result in contract charges, income taxes, and tax penalties.

Qualified Contracts.  You may purchase the contract as an IRA, Roth IRA, SIMPLE IRA, SEP IRA, Tax Sheltered Annuity (“TSA”), Roth TSA or Deferred Compensation Plan (“457”), which we also refer to as qualified contracts because

they are qualified to provide you certain tax deferral features under the Internal Revenue Code. You do not have to purchase an annuity contract to obtain the same type of tax deferral as provided by other qualified retirement arrangements. However, the contract provides features and benefits not provided by such other arrangements. There are costs and expenses under the contract related to these benefits and features. You should consult your tax advisor to determine whether the use of the contract within a qualified retirement plan is an appropriate investment for you. Access to amounts held in qualified contracts may be restricted or prohibited.

Exchanges.  It may not be in your best interest to surrender an existing annuity contract or to exchange one annuity contract for another in a “tax-free” exchange under Section 1035 of the Internal Revenue Code of 1986, as amended, in connection with a purchase of the contract. You should compare both contracts carefully. There may be a surrender charge on your old contract, there will be a new surrender charge period under this contract, other charges may be higher (or lower), and the benefits will probably be different. You should not exchange another annuity contract for this one unless you determine, after knowing all of the facts, that the exchange is in your best interest and not just better for the person trying to sell you this contract (that person will generally be paid a commission if you buy this contract through an exchange or otherwise).

State Variations.  Certain provisions of the contract may be different from the general description in this prospectus, and certain riders and options may not be available, because of legal restrictions in your state. See your contract for specific variations since any such state variations will be included in your contract or in riders or endorsements attached to your contract. See your agent or contact us for specific information that may be applicable to your state.

INQUIRIES

If you need more information, please contact us at our “Home Office”:

Symetra Life Insurance Company

777 108th Avenue NE, Suite 1200

Bellevue, WA 98004

1-800-796-3872

http://www.symetra.com

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FEE TABLE

The purpose of the Fee Table is to show you the various fees and expenses you will incur directly and indirectly by buying, owning, and surrendering the contract. The Fee Table reflects the expenses of the Separate Account as well as the Portfolios.

The Owner Transaction Expenses table describes the fees and expenses that you will pay when you make withdrawals or transfer money between Sub-accounts. State Premium Taxes may also be deducted.

OWNER TRANSACTION EXPENSES	AMOUNT DEDUCTED
SURRENDER CHARGE (1) (2) (3) (As a percentage of the Purchase Payment withdrawn based on complete years elapsed since the receipt of the Purchase Payment )	Years Elapsed: Percentage:	0 7%	1 7%	2 7%	3 6%	4 6%	5 5%	6 4%	7 0%
WITHDRAWAL CHARGE (4) (Assessed for each withdrawal after the first withdrawal in a Contract Year)	$25
TRANSFER CHARGE (Assessed for each transfer in excess of 12 transfers in a Contract Year)	$10 or 2% of amount transferred whichever is less

(1) Surrender charges may be reduced if contracts are sold to a large group of individuals.

(2) The aggregate of the surrender charge and withdrawal charge will not exceed 9% of Purchase Payments.

(3) We eliminate this charge for individual retirement annuities purchased with rollovers of $20,000 or more from employer-sponsored plans that own group variable annuities issued by us.

(4) The withdrawal charge is assessed in addition to any applicable surrender charge. We eliminate this charge for withdrawals taken through electronic funds transfer (“EFT”), annuity payments, repetitive withdrawals or if you withdraw the entire Contract Value.

The Periodic Charges table below describes the fees and expenses that you will pay periodically during the time that you own the contract, not including Portfolio fees and expenses.

PERIODIC CHARGES Shown As An Annual Rate or Amount (Not Including Portfolio Operating Fees and Expenses or Optional Benefit Charges)	MAXIMUM AMOUNT DEDUCTED	CURRENT AMOUNT DEDUCTED
ANNUAL ADMINISTRATION MAINTENANCE CHARGE (5) (Deducted from Contract Value)	$50	$40
SEPARATE ACCOUNT ANNUAL EXPENSES (As a percentage of average daily net assets of each Sub-account/deducted daily)
Mortality And Expense Risk Charge Asset Related Administration Charge (6)	0.95% 0.40%	0.95% 0.40%
TOTAL SEPARATE ACCOUNT ANNUAL EXPENSES	1.35%	1.35%

(5) We do not deduct this charge if the Contract Value is at least $50,000 when the deduction is to be made.

(6) The asset-related administration charge is based upon your Contract Value as of the start of each Contract Year. Your asset-related administration charge may be less than the maximum charge of 0.40%. Please see the chart below for the range of charges.

ASSET-RELATED ADMINISTRATION CHARGE (deducted daily and shown here as an annual rate)
Contract Value	$0 to $99,999.99	$100,000.00 to $249,999.99	$250,000.00 to $499,999.99	$500,000.00 to $999,999.99	$1 million or more
Charge	0.40%	0.35%	0.25%	0.15%	0.05%

The Charges For Optional Benefit Riders table below describes the fees and expenses that you would pay if you added optional benefits to your contract.

ANNUAL CHARGES FOR OPTIONAL BENEFIT RIDERS (as a percentage of the average daily net assets of each Sub-account/deducted daily)	MAXIMUM CHARGE	CURRENT  CHARGE
GUARANTEED MINIMUM DEATH BENEFIT AGE EXTENSION	0.10%	0.10%
	MAXIMUM CHARGE (deducted annually on each contract anniversary for the first 10 Contract Years)
GUARANTEED LONG LIFE BENEFIT RIDER (as a percentage of Purchase Payments) (7)	5% of Purchase Payments received  in the first Contract Year

(7) The actual dollar amount deducted for the charge and its percentage of first year Purchase Payments will vary for each contract based on the amount of the Long Life Benefit Payment selected, the Long Life Benefit Annuitant’s age and sex, the deferral period chosen, the amount of the first year Purchase Payments, and current interest rates and mortality tables. We will reduce your Long Life Benefit Payment on the first contract anniversary if Purchase Payments received by this date would cause you to exceed the maximum 5% charge. Please see the “Optional Benefit Charges” sub-section of “Section 5 - Charges and Expenses” of this prospectus for more details.

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The Total Annual Portfolio Expense Table shows the lowest and highest total operating expenses charged by the Portfolio companies that you pay indirectly during the time you own the contract. The total operating expenses are expressed as an annual percentage of average daily net assets and are deducted from Portfolio assets. The amounts are based on expenses paid as of the end of the fiscal year December 31, 2009. Actual expenses in the future may be higher or lower. For Portfolios that invest in shares of one or more acquired funds, the total annual operating expenses include fees and expenses incurred indirectly by the Portfolio as a result of investment in shares of one or more acquired funds. The fees and expenses (including management fees, distribution (12b-1) fees and other expenses) for each individual Portfolio are contained in the prospectuses for each Portfolio.

TOTAL ANNUAL PORTFOLIO OPERATING EXPENSES (8)	Lowest	Highest
Range of total annual portfolio operating expenses (before any waivers or expense reimbursement)	0.10%	1.49%
Range of total annual portfolio operating expenses (after any waiver or expense reimbursement) (9)	0.10%	0.69%

(8) We reserve the right to implement, administer, and charge you for any fee or restriction, including redemption fees which may be imposed by any underlying Portfolio.

(9) The range of total annual Portfolio operating expenses after any waiver or expense reimbursement takes into account contractual arrangements for certain Portfolios that require the investment advisor to reimburse or waive Portfolio operating expenses until at least April 30, 2011. Advisors to certain Portfolios offered in the contract agree to waive or reimburse advisory fees or other fees. This reduces Portfolio operating expenses. Such arrangements are described in more detail in the prospectus for each Portfolio.

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EXAMPLES

These examples are intended to help you compare the cost of investing in the contract with the cost of investing in other variable annuity contracts. These costs include contract Owner transaction expenses, contract fees, Separate Account annual expenses (including the mortality and expense risk charge, the asset-related administration charge and if applicable any additional riders), and the Portfolio fees and expenses.

For purposes of calculating the examples, we use an average annual administration maintenance charge based on the charges paid in 2009. We based annual expenses of the underlying Portfolios on data provided by the Portfolio companies for the year ended December 31, 2009. The examples do not reflect premium taxes that may apply depending on the state where you live, and assume no transfers or partial withdrawals. The examples do not take into consideration any fee waiver or reimbursement arrangements of the underlying Portfolios. If these arrangements were taken into consideration, the expenses shown would be lower. We did not independently verify the data provided; but we did prepare the examples.

Different fees may be imposed during the Income Phase. Please see “Section 5 - Charges and Expenses” for a more detailed description.

The examples should not be considered a representation of past or future expenses. Your actual costs may be higher or lower. The 5% annual return assumed in the examples is purely hypothetical. Actual returns (investment performance) will vary and may be more or less than 5%.

EXAMPLES WITH ALL RIDERS (1)

You would pay the following expenses on a $10,000 investment in the contract for the time periods indicated below assuming that you elect all optional benefit riders available under the contract and your investment has a 5% return each year.

THE FOLLOWING EXAMPLE ASSUMES THE HIGHEST FEES AND EXPENSES OF ANY OF THE PORTFOLIOS.

If You Surrender Your Contract At The End of Each Time Period
1 Year	3 Years	5 Years	10 Years
$1,410	$2,940	$4,355	$7,555

If The Contract Is Not Surrendered or Is Annuitized
1 Year	3 Years	5 Years	10 Years
$799	$2,369	$3,901	$7,555

THE FOLLOWING EXAMPLE ASSUMES THE LOWEST FEES AND EXPENSES OF ANY OF THE PORTFOLIOS.

If You Surrender Your Contract At The End of Each Time Period
1 Year	3 Years	5 Years	10 Years
$1,287	$2,593	$3,803	$6,541

If The Contract Is Not Surrendered or Is Annuitized
1 Year	3 Years	5 Years	10 Years
$668	$1,995	$3,310	$6,541

(1) The examples are based on the maximum charge of 0.10% for the GMDB-Age Extension Rider, and 5% for the Guaranteed Long Life Benefit Rider. The amount of Long Life Benefit Payment that the GLLB Rider charge of 5% will purchase will vary by contract and is based on the Long Life Benefit Annuitant’s age and sex, the deferral period chosen, the amount of the first year Purchase Payments, and current interest rates and mortality tables.

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EXAMPLES WITH STANDARD FEATURES

You would pay the following expenses on a $10,000 investment in the contract for the time periods indicated below assuming that your investment has a 5% return each year.

THE FOLLOWING EXAMPLE ASSUMES THE HIGHEST FEES AND EXPENSES OF ANY OF THE PORTFOLIOS.

If You Surrender Your Contract At The End of Each Time Period
1 Year	3 Years	5 Years	10 Years
$932	$1,554	$2,102	$3,169

If The Contract Is Not Surrendered or Is Annuitized
1 Year	3 Years	5 Years	10 Years
$289	$885	$1,505	$3,169

THE FOLLOWING EXAMPLE ASSUMES THE LOWEST FEES AND EXPENSES OF ANY OF THE PORTFOLIOS.

If You Surrender Your Contract At The End of Each Time Period
1 Year	3 Years	5 Years	10 Years
$804	$1,170	$1,455	$1,782

If The Contract Is Not Surrendered or Is Annuitized
1 Year	3 Years	5 Years	10 Years
$152	$472	$815	$1,782

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1. THE ANNUITY CONTRACT

This prospectus describes a variable annuity contract offered by Symetra Life.

The annuity contract is an agreement between Symetra Life and you, the Owner, where we promise to pay an income in the form of annuity payments, beginning on a date you select, or a death benefit. When you are investing money, your contract is in the Accumulation Phase. Once you begin receiving annuity payments, your contract is in the Income Phase.

Contracts owned by or for individuals generally benefit from tax deferral under the Internal Revenue Code of 1986, as amended (“Code”). You can change your investment allocation or transfer between Sub-accounts without paying tax on contract earnings until you withdraw money from the contract.

The contract is called a variable annuity because you can choose among the available Sub-accounts. Each Sub-account invests in a corresponding Portfolio and you can make or lose money depending upon market conditions. The investment performance of the Sub-account(s) you select affects the value of your contract and, therefore, affects the amount of the annuity payments available at the time of annuitization. Investment performance of the Sub-account(s) also impacts the amount of any variable annuity payments. You may also choose fixed annuity payments. Unlike variable annuity payments, once the Income Phase begins fixed annuity payments are not affected by the investment performance of the Sub-accounts.

OWNER

The Owner (“you”) is as shown on the contract application, unless changed. You, as the Owner, may exercise all ownership rights under the contract. The contract must be issued prior to the Owner reaching the maximum issue age as stated in the contract. In certain situations, we may preserve a younger age on your contract. If your birthday falls between the application date and the Contract Date, we will issue the contract based upon your age as of the application date if requested by you and subject to state regulations.

A non-qualified contract can be owned by joint Owners unless you have purchased the contract with the GLLB Rider. Each joint Owner has equal ownership rights and must exercise those rights jointly, unless both joint Owners direct us otherwise in writing. Naming joint Owners can have a negative impact on the death benefit. See “Section 9 - Death Benefit and Optional Death Benefit Rider.”

An Owner who is a non-natural person (e.g., a corporation or a trust) may not name a joint Owner. You may change the Owner or joint Owner by sending us a signed and dated request. If you designate someone else as Owner, that person must not have been older than the maximum issue age on the Contract Date. Unless you specify otherwise, a change in ownership is effective as of the date you signed the notice of change, subject to any payments made or actions we may take prior to receipt of the notice.

Use care when naming joint Owners and Beneficiaries and consult your agent or other advisor if you have questions.

ANNUITANT

The Annuitant is the person or persons on whose life/lives annuity payments are based. You are the Annuitant unless you designate someone else before the Annuity Date. If you designate someone else as Annuitant, that person must not be older than the maximum issue age as stated in the contract on the Contract Date. Owners who are non-natural persons (e.g., corporations or trusts) may not change the Annuitant. If a non-natural Owner chooses the GLLB Rider, then the Annuitant will also be the Long Life Benefit Annuitant. Annuity payments must begin prior to the Annuitant reaching the maximum annuitization age as stated in the contract.

PAYEE

The Payee is the person or persons designated by you to receive annuity payments under the contract. If the GLLB Rider is elected, the Payee would receive any Long Life Benefit Payments under the rider. You are the Payee unless you designate another person as the Payee. As the Owner, you may change the Payee at any time.

BENEFICIARY

The Beneficiary is the person or entity that is entitled to receive a benefit as described in “Section 9 - Death Benefit and Optional Death Benefit Rider.” You initially name the Beneficiary on your contract application and it can be changed at any time (by sending a signed and dated request) unless you have designated the Beneficiary as irrevocable. An irrevocable Beneficiary must consent in writing to any change. A new Beneficiary designation revokes any prior designation and is effective when signed by you. We are not responsible for the validity of any Beneficiary designation nor for any actions we may take prior to receiving and recording a Beneficiary change. In the case of certain contracts issued in connection with retirement plans, the retirement plan may prescribe certain limitations on the designation of a Beneficiary. After your death, the Beneficiary has the right to receive the death benefit or to change the Payee for remaining annuity payments. Thus, Beneficiaries should notify us of a death as promptly as possible.

ASSIGNMENT

You can assign the contract unless restricted by applicable law; however, the new Owner cannot be older than the maximum issue age on the Contract Date. Assignments may result in current taxation and, if you are under age 59 ¹/2, a 10% tax penalty. If this contract is assigned, we will treat it as a change of ownership and all rights will be transferred. We are not bound by any assignment unless it is in writing. Assignments are effective on the date you sign the notice of assignment, subject to all payments made and actions we take before we receive a signed copy of the assignment form at our Home Office. We are not liable for payments made prior to receipt of an effective assignment. We are not responsible for the validity of any assignments, tax consequences, or actions we may take based on an assignment later determined to be invalid.

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Assigning the contract or changing the Owner can have a negative impact on the death benefit. See “Section 9 - Death Benefit and Optional Death Benefit Rider.”

If your contract is an Individual Retirement Annuity (“IRA”) or otherwise issued in connection with a tax-qualified retirement plan, your ability to assign the contract may be limited.

2. ANNUITY PAYMENTS (INCOME PHASE)

You can switch to the Income Phase at any time after the contract has been in effect for one year by notifying us in writing at least 30 days prior to the date that you want annuity payments to begin. However, the Income Phase will start no later than the maximum annuitization age of 95, or earlier if required by law and certain restrictions may apply under some retirement plans.

During the Income Phase, the Payee (you or someone you choose) will receive annuity payments beginning on the Annuity Date. You name the Payee when you elect an annuity option and you may change the Payee designation at any time by writing to us. You may select or change an annuity option at any time prior to switching to the Income Phase by completing an election form that you can request in writing or by phone from us at any time or by downloading the form from our web site. Some retirement plans and/or contract versions require that the Annuitant be the Owner and Payee once annuity payments begin.

Switching to the Income Phase is irrevocable. Once you begin receiving annuity payments, you cannot switch back to the Accumulation Phase. During the Income Phase, you cannot add Purchase Payments, make withdrawals, change or add an Annuitant, change the annuity option, or change between fixed and variable annuity payments. When the contract switches to the Income Phase, the guaranteed minimum death benefit will no longer be applicable and there will generally be no death benefit. If you transfer the right to receive annuity payments to someone else, there may be gift and income tax consequences. If premium taxes are required by state law, these taxes will be deducted from your Contract Value before the annuity payments are calculated.

Annuity payments will begin on the earlier of:

• the first available payment date after you elect to begin annuity payments;

• the latest Annuity Date specified in your contract; or

• a different Annuity Date if required by law.

PAYMENT OPTIONS

Other than the Period Certain Annuity, you may choose whether annuity payments will be made on a fixed basis, variable basis, or both. Period certain annuities are available only on a fixed basis. If you don’t choose an annuity option, payments will be made on a variable basis. Annuity options made on a variable basis convert Accumulation Units to Annuity Units on the date you switch to the Income Phase.

Once annuity payments under a life annuity option are started, they cannot be exchanged for a lump sum. See the Statement of Additional Information (SAI) for additional information.

ANNUITY OPTIONS

You may choose one of the options listed below. The amount of each annuity payment depends on many factors including the guarantees, if any, under the annuity option you choose, the frequency of annuity payments, the investment performance if you choose variable annuity payments, the Annuitant’s age at the time you switch to the Income Phase, and, under some contracts, the Annuitant’s sex. If you choose a life annuity option, the number of annuity payments the Payee receives depends on how long the Annuitant lives, not the Annuitant’s life expectancy. The available annuity options are as follows:

Life Annuity.  The Payee receives monthly annuity payments as long as the Annuitant is living. Annuity payments stop when the Annuitant dies. There is no minimum number of payments with this option.

Life Annuity with Guaranteed Period.  The Payee receives monthly annuity payments for the longer of the Annuitant’s life or a guaranteed period of five or more years, as selected by you and agreed to by us. Annuity payments stop on the later of the date the Annuitant dies or the date the last guaranteed payment is made. The amount of the annuity payments may be affected by the length of the guaranteed period you select. A shorter guaranteed period will result in higher annuity payments during the Annuitant’s life and fewer or no remaining guaranteed payments to the Payee. A longer guaranteed period will result in lower annuity payments. If the Annuitant dies before the guaranteed payments have been made, the remaining payments will be made to the Payee. As an alternative to monthly payments, the Payee may elect to have the variable payments remaining commuted at the assumed interest rate of 4% and paid in a single lump sum. This alternative is not available for fixed payments.

Joint and Survivor Life Annuity.  The Payee receives monthly annuity payments as long as the Annuitant is living. After the Annuitant dies, the Payee receives a specified percentage of each annuity payment as long as the joint Annuitant is living. Annuity payments stop the later of the date the Annuitant dies or the date the joint Annuitant dies. You name the joint Annuitant and payment percentage at the time you elect this option and they can not be changed once the Income Phase begins. Choosing a lower percentage amount to be paid after the death of the Annuitant and while the joint Annuitant is living results in higher payments while both Annuitants are living.

Joint and Survivor Life Annuity with Guaranteed Period.  The Payee receives annuity payments for the longer of the Annuitant’s life, the joint Annuitant’s life or a guaranteed period of 5 or more years, whichever is longer. If the Annuitant dies before the period ends, the full benefit amount will continue to be paid to the Payee until the period ends. If the joint Annuitant is alive when

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the guaranteed period ends, a percentage of the payment amount will continue to be paid to the Payee as long as the joint Annuitant is alive. You name the joint Annuitant, Payee and payment percentage at the time you elect this option. The joint Annuitant and payment percentages cannot be changed once the Income Phase begins. Choosing a lower percentage amount to be paid after the death of the Annuitant and while the joint Annuitant is living results in higher payments while both Annuitants are living. If both the Annuitant and joint Annuitant die before the end of the guaranteed period, the remaining payments will be made until the end of the guaranteed period to the Payee, unless you designate a new Payee.

Period Certain Annuity.  The Payee receives monthly annuity payments for a specific period of time, usually 5, 10, 15, or 20 years. This guaranteed period may not exceed the annuitant’s life expectancy. This option does not guarantee payments for the rest of the Annuitant’s life. This payout option is available only as a fixed annuity. If your contract is a qualified contract, period certain payments without a life contingency may not satisfy minimum required distribution rules. Consult a tax advisor before electing this option.

If you do not choose an annuity option at least 30 days before the latest Annuity Date specified in your contract, we will make variable annuity payments under the Life Annuity with Guaranteed Period using a guaranteed period of 10 years.

Unless noted, annuity payments will be made on a monthly basis unless you tell us otherwise. You may choose to have annuity payments made on a monthly, quarterly, semi-annual or annual basis. If state law allows, we may choose to distribute your Contract Value of $2,000 or less in a lump sum rather than providing you annuity payments. We also reserve the right to change the payment frequency if payment amounts would be less than $250. You may elect to have payments delivered by mail or electronically transferred to a bank account.

Proof of Age or Sex:  We may require proof of age or sex before beginning annuity payments that are based on life. If the age or sex of any Annuitant has been misstated, annuity payments will be based on the corrected information. Underpayments will be made up in a lump sum with the next scheduled payment. Overpayments will be deducted from future payments until the total is repaid. We will not credit interest on underpayments or charge interest on overpayments. We may require evidence satisfactory to us that an Annuitant is living before we make any payment.

Variable Annuity Payments.  Any portion of annuity payments based on investment in the Sub-accounts will vary in amount depending on investment performance. Unless you tell us otherwise, annuity payments will be based on the investment allocations in place on the date you switch to the Income Phase.

If you choose to have any portion of annuity payments based on investment in the Sub-accounts, the dollar amount of each payment will depend on:

• the value of your contract in the Sub-accounts as of the first close of the New York Stock Exchange (“NYSE”) on or after the 15^th day of the month preceding the Annuity Date (if the NYSE is not open on that date, the calculation will be made on the next Business Day);

• an assumed investment return; and

• the investment performance of the Sub-accounts you selected.

Your contract contains a Variable Annuity Purchase Rate Table that we use to determine the amount of the first annuity payment under your contract. The tables are based on an annual investment return of 4% and the Annuity 2000 Mortality Table. The amount of the first annuity payment is generally determined on the basis of the annuity option selected, the annuity purchase rate (as shown in your contract’s Variable Annuity Purchase Rate Table), the age and sex of the Annuitant, and the Annuity Date. If actual investment performance of the Sub-accounts exceeds the assumed investment return of 4%, the value of Annuity Units increases and the next variable annuity payment will be larger. Similarly, if the actual investment performance is less than the assumed investment return, the value of Annuity Units decreases and the next variable annuity payment will be smaller. Under any variable annuity option, actual investment performance of the Sub-accounts will affect the amount of annuity payments. For more information, please see the SAI.

Fixed Annuity Payments.  The dollar amount of fixed annuity payments does not vary with investment performance, therefore, each payment amount will stay the same. Annuity payments under all life annuity options will be determined by applying the Contract Value or a portion of the Contract Value to purchase fixed annuity payments to the Fixed Annuity Purchase Rate Table shown in your contract, or the current rates at that time if more favorable to you.

CHANGING SUB-ACCOUNTS DURING THE INCOME PHASE

After you switch to the Income Phase and while you are receiving variable annuity payments, you may request to change Sub-account elections only once a month. We make all annuity payments on the 1^st of the month, and those payments are calculated based on the unit value as of the close of the NYSE on the 15^th of the preceding month. Once we have calculated the amount of your annuity payment for the current month, we determine the amount of Annuity Units in the newly elected Sub-account which that amount will purchase. The number of units in the new Sub-account will be used to determine future annuity payments, unless another allocation change is requested. Your payment will not change amounts in the current month, however, future payments will be based upon the new selection thereafter.

Example:  Assume that your variable annuity payments have been based on allocations in Sub-account A and you have 20 units. When we calculate your payment, we determine that the value of an Accumulation Unit for

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Sub-account A on the close of the NYSE on the 15th of the month is $35.00. We then multiply the 20 units held on the 15th by the unit value of $35.00 and calculate a payment to you in the amount of $700. This is the amount of your payment for the month.

We then make your allocation change to Sub-account B, and determine the number of units in Sub-account B is worth $700. Assuming the unit value of Sub-account B is $25.00, you will now have 28 units in Sub-account B ($700 divided by $25 = 28). For future months, your payments will be based upon the 28 units held in Sub-account B multiplied by the unit value of Sub-account B. Therefore, your payments will fluctuate based on the performance of Sub-account B.

3. PURCHASE

PURCHASE PAYMENTS

If you are age 85 or younger, you may purchase a contract with a minimum initial Purchase Payment of $10,000. Additional Purchase Payments of $10,000 or more may be added at anytime during the Accumulation Phase. We will not accept any Purchase Payments that are less than $10,000. For IRAs and Roth IRAs, because the minimum Purchase Payment we accept exceeds the contribution limits for IRAs and Roth IRAs, only rollover contributions are accepted.

Any Purchase Payment in excess of $1 million requires our prior approval.

Initial Purchase Payments:  Initial Purchase Payments must be forwarded to our Home Office and are normally credited to your contract within two Business Days of our receipt. Processing of initial Purchase Payments may be delayed by circumstances outside our control, for example, if your registered representative does not forward your application and initial Purchase Payment to us promptly. If your initial Purchase Payment is not accompanied by all the information we need to issue your contract, we will contact you to get it. If we cannot get all the required information within five Business Days, we will either return your initial Purchase Payment or get your or your registered representative’s permission to keep it until we have received the necessary information. However, if the necessary information is not received after 15 Business Days, we will reject your application and return the initial Purchase Payment to you. In most situations, your Contract Date is the date your initial Purchase Payment and all required information are received at our Home Office. We reserve the right to refuse any application or initial Purchase Payment. If we refuse an application and initial Purchase Payment, we will return it to you within five Business Days.

Additional Purchase Payments:  Additional Purchase Payments may be made at any time by sending them to our Home Office and should include your account number. Additional Purchase Payments made by check, mailed to our Home Office and received with all the information we need to process them are credited to your contract on the same Business

Day as received by us. However, if your Purchase Payment is received at our Home Office after the close of the NYSE, any portion to be allocated to the Sub-accounts will be credited the next Business Day. Processing of Purchase Payments may be delayed by circumstances outside our control - for example, if your registered representative does not forward your Purchase Payments to us promptly. In addition, if your Purchase Payment is received without the necessary information we need to process it, processing delays will occur as we attempt to contact you to get the necessary information. If we cannot get all the required information within five Business Days, we will either return your Purchase Payment or get your or your registered representative’s permission to keep it until we have received the necessary information. However, if the necessary information is not received after 15 Business Days, we will return the Purchase Payment.

We reserve the right to refuse any Purchase Payment that is over $1 million dollars; that does not meet our minimum of $10,000; that is received without the necessary information to process the payment; that is made for market timing purposes; or is otherwise contrary to law for Symetra Life to accept. If we refuse a Purchase Payment, we will return it to you within five Business Days. We will not deem payments sent to any other office besides our Home Office as received by us until such payment reaches our Home Office.

ALLOCATION OF PURCHASE PAYMENTS

You tell us how to apply your initial Purchase Payment by specifying your desired allocation among the available Sub-accounts on the contract application. Unless you tell us otherwise, subsequent Purchase Payments will be allocated in the same proportion as your most recent Purchase Payment (unless that was a Purchase Payment you directed us to allocate on a one-time-only basis). You may change the way subsequent Purchase Payments are allocated by providing us with written instructions, or, by telephoning us or electronically by the Internet if we have your written authorization to accept telephone or Internet instructions. See “Transfers” as discussed in Section 4.

ACCUMULATION UNITS

The value of your contract will go up or down depending upon the investment performance of the Sub-account(s) you choose. In order to keep track of this we use a unit of measure called an Accumulation Unit. During the Income Phase, we call the unit of measure an Annuity Unit.

We calculate the value of an Accumulation Unit for each Sub-account as of the time the NYSE closes each day. To determine the current Accumulation Unit value, we take the prior day's Accumulation Unit value and multiply it by the Net Investment Factor for the current day. Changes in the Accumulation Unit value reflect the investment performance of each Sub-account as well as the deductions for insurance and other charges. The value of an Accumulation Unit will usually go up or down from day to day.

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The Net Investment Factor is used to measure the daily change in Accumulation Unit value for each Sub-account. The Net Investment Factor equals:

• the net asset value per share of the applicable Portfolio at the end of the current day plus the per share amount of any dividend or income distributions made by the Portfolio that day; divided by

• the net asset value per share of the Portfolio at the end of the prior day plus the per share amount of any dividend or income distributions made by the Portfolio that day; minus

• the daily insurance charges and any taxes Symetra Life may incur on earnings attributable to the applicable contracts, expressed as a percentage of the total net assets of the Sub-account.

When you make Purchase Payments or transfers into a Sub-account, we credit your contract with Accumulation Units. We determine the number of Accumulation Units to credit by dividing the amount of the Purchase Payment allocated to a Sub-account by the value of the Accumulation Unit for that particular Sub-account. Similarly, when you request a withdrawal or a transfer of money from a Sub-account, we deduct from your contract Accumulation Units representing the withdrawal amount.

Example:  Assume that on Monday we receive a $10,000 Purchase Payment from you before the NYSE closes. You have told us you want this to go to the Fidelity VIP Index

500 Portfolio. When the NYSE closes on that Monday, we determine that the value of an Accumulation Unit for the Fidelity VIP Index 500 Portfolio is $34.12. We then divide $10,000 by $34.12 and credit your contract on Monday night with 293.10 Accumulation Units for the Fidelity VIP Index 500 Portfolio.

RIGHT TO EXAMINE

You may cancel the contract without charge by returning it to us or to your registered representative within the period stated on the front page of your contract. We include a refund of all charges that may have been deducted from your contract if you request to cancel your contract during this period. This period will be at least 10 days (longer in some states). You will receive your Contract Value, a return of Purchase Payments, or the greater of the two depending on state requirements. Because of the market risks associated with investing in the Sub-accounts, the Contract Value returned may be more or less than the Purchase Payments you have paid. Some states require us to return to you the amount of the Purchase Payments paid to us. In which case, Symetra Life will be subject to the investment risk. When we are required to guarantee a return of Purchase Payments or to give you a choice between a refund of Contract Value or return of Purchase Payments, we will apply amounts designated for the Sub-accounts to the Fidelity VIP Money Market until the contract is 15 days old (or 30 days in those states where a 30-day period is required). These amounts will then be allocated in the manner you selected unless you have canceled the contract.

4. SUB-ACCOUNT OPTIONS

SUB-ACCOUNT OPTIONS

During the Accumulation Phase, you may allocate your Purchase Payments and Contract Value to any of the Sub-accounts available under the contract. Each Sub-account purchases the shares of one underlying Portfolio that has its own investment objective. The Portfolios are not offered directly to the public, but are available to life insurance companies as investment options for variable annuity and variable life insurance contracts.

The following Portfolios are currently offered to contract Owners. The name, investment objective, and investment advisor of the Portfolios offered under this contract are listed below. There is no assurance that any of the Portfolios will achieve their stated objective. You can find more detailed information about the Portfolios, including a description of risks and expenses, in the prospectuses for the Portfolios, which can be obtained without charge by contacting our Home Office. You should read those prospectuses carefully before investing. The Portfolio information below was provided by the Portfolios. We have not independently verified the accuracy of the information.

PORTFOLIO NAME	INVESTMENT OBJECTIVE	INVESTMENT ADVISOR
DWS Investments VIT Funds
DWS Small Cap Index VIP	The fund seeks to replicate, as closely as possible, before the deduction of expenses, the performance of the Russell 2000® Index, which emphasizes stocks of small US companies. Under normal circumstances, the fund invests at least 80% of its assets, determined at the time of purchase, in stocks of companies included in the Russell 2000 Index® and in derivative instruments, such as stock index futures contracts and options that provide exposure to the stocks of companies in the index.	Deutsche Investment Management Americas Inc. is the investment advisor for the fund. Northern Trust Investments, N.A. (“NTI”), is the subadvisor for the fund.

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PORTFOLIO NAME	INVESTMENT OBJECTIVE	INVESTMENT ADVISOR
Fidelity® Variable Insurance Products
Fidelity VIP Index 500 Portfolio	Fidelity VIP Index 500 Portfolio seeks investment results that correspond to the total return of common stocks publicly traded in the United States, as represented by the S&P 500.	Fidelity Management & Research Company
Fidelity VIP Money Market Portfolio	Fidelity VIP Money Market Portfolio seeks as high a level of current income as is consistent with preservation of capital and liquidity.	Fidelity Management & Research Company
Ibbotson ETF Allocation Series
Ibbotson Aggressive Growth ETF Asset Allocation Portfolio	The Portfolio seeks to provide investors with capital appreciation.	ALPS Advisors, Inc. Sub-Advised by Ibbotson Associates, Inc.
Ibbotson Balanced ETF Asset Allocation Portfolio	The Portfolio seeks to provide investors with capital appreciation and some current income.	ALPS Advisors, Inc. Sub-Advised by Ibbotson Associates, Inc.
Ibbotson Conservative ETF Asset Allocation Portfolio	The Portfolio seeks to provide investors with current income and preservation of capital.	ALPS Advisors, Inc. Sub-Advised by Ibbotson Associates, Inc.
Ibbotson Growth ETF Asset Allocation Portfolio	The Portfolio seeks to provide investors with capital appreciation.	ALPS Advisors, Inc. Sub-Advised by Ibbotson Associates, Inc.
Ibbotson Income and Growth ETF Asset Allocation Portfolio	The Portfolio seeks to provide investors with current income and capital appreciation.	ALPS Advisors, Inc. Sub-Advised by Ibbotson Associates, Inc.
The Ibbotson Portfolios listed above are “Fund of Funds” and seek to achieve their investment objectives by investing primarily in portfolios of underlying exchange-traded funds which are open end mutual funds that can be traded at any time of the day (each, an “Underlying ETF” and collectively, the “Underlying ETFs”). These Underlying ETFs, in turn, invest in a variety of U.S. and foreign equity, debt, commodities, money market securities, futures and other instruments in an attempt to approximate the investment performance of the applicable benchmark. Fund-of-Funds have higher expenses compared to other Portfolios and therefore may be more expensive to contract Owners.
Vanguard® Variable Insurance Fund Portfolios Vanguard is a registered trademark of The Vanguard Group
Vanguard VIF - Balanced Portfolio	The Balanced Portfolio seeks to provide long-term capital appreciation and reasonable current income.	The Vanguard Group, Inc.
Vanguard VIF - High Yield Bond Portfolio	The High Yield Bond Portfolio seeks to provide a high level of current income.	The Vanguard Group, Inc.
Vanguard VIF - International Portfolio	The International Portfolio seeks to provide long-term capital appreciation.	The Vanguard Group, Inc.
Vanguard VIF - Mid-Cap Index Portfolio	The Mid-Cap Index Portfolio seeks to track the performance of a benchmark index that measures the investment return mid-capitalization stocks.	The Vanguard Group, Inc.
Vanguard VIF - REIT Index Portfolio	The REIT Index Portfolio seeks to provide a high level of income and moderate long-term capital appreciation by tracking the performance of a benchmark index that measures the performance of publicly traded equity Real Estate Investment Trusts.	The Vanguard Group, Inc.
Vanguard VIF - Total Bond Market Index Portfolio	The Total Bond Market Index Portfolio seeks to track the performance of a broad, market-weighted bond index.	The Vanguard Group, Inc.
Vanguard VIF - Total Stock Market Index Portfolio	The Total Stock Market Index Portfolio seeks to track the performance of a benchmark index that measures the investment return of the overall stock market.	The Vanguard Group, Inc.
The Vanguard VIF - Total Stock Market Index Portfolio is a “Fund of Funds,” which means that it achieves its objective by investing in other mutual funds rather than in individual securities. Fund of Funds have higher expenses compared to other Portfolios and therefore may be more expensive to contract Owners.

In addition to selling shares to the Separate Account, the Portfolios may sell shares to other separate accounts of other insurance companies to support variable annuity contracts and variable life insurance contracts or qualified retirement plans. It is possible that, in the future, it may be disadvantageous for variable life insurance separate accounts and variable annuity separate accounts of other companies to invest simultaneously in the Portfolios. Currently, neither we nor the Portfolios foresee any such disadvantages to variable life insurance owners or variable annuity owners. The Portfolios must monitor

events to identify material conflicts between such owners and determine what action, if any, should be taken. In addition, if we believe a Portfolio’s response to any of those events or conflicts insufficiently protects contract Owners, we will take appropriate action. For more information about the risks associated with the use of the same funding vehicle for both variable annuity and variable life insurance contracts of various insurance companies and/or qualified retirement plans, see the prospectuses of the Portfolios that are available upon request if they do not accompany this prospectus.

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The investment performance for the Portfolios may differ substantially from publicly traded mutual funds with similar names and objectives. There can be no assurance, and we make no representation, that the investment performance of the Portfolios will be comparable to any other Portfolio, even those with the same investment objectives and policies and advisor or manager. Certain Portfolios available through the contract have names similar to funds not available through the contract. The performance of a fund not available through the contract does not indicate performance of a similarly named Portfolio available through the contract. Differences in fund size, actual investments held, fund expenses, and other factors all contribute to differences in fund performance. For all these reasons, you should expect investment results to differ.

Please note that there can be no assurance that any money market fund will be able to maintain a stable net asset value per share. During extended periods of low interest rates, and due in part to contract fees and expenses, the yields of any Sub-account investing in a money market fund may also become extremely low and possibly negative.

CHANGES TO THE SUB-ACCOUNTS

We reserve the right to add, combine, restrict, or remove any Sub-account in which any Portfolio is invested as an investment option under your contract. If any shares of the Portfolios are no longer available, or if in our view no longer meet the purpose of the contract, it may be necessary to substitute shares of another Portfolio. New or substitute Portfolios may have different fees and expenses and their availability may be limited to certain classes of purchasers. It may also be necessary to close Portfolios to allocations of new Purchase Payments by existing or new contract Owners and we reserve the right to do so at any time and in our discretion. We will seek prior approval of the SEC (to the extent required by law) and give you notice before making any changes to the investment options.

COMPENSATION WE RECEIVE FROM PORTFOLIOS

We have agreements with each of the Portfolio advisors or their affiliates that describe the administrative practices and responsibilities of the parties. We receive compensation from some or all of the Portfolios or their investment advisors, administrators, and/or distributors (or their affiliates) in connection with administrative or other services provided with respect to the Portfolios. We may use this compensation for any purpose, including paying expenses that we incur in promoting, issuing, distributing and administering the contract. We also receive this compensation for providing services to contract Owners invested in the Portfolios on behalf of the Portfolios. The amounts we receive, if any, may be different for different Portfolios, and usually depends on how much we have invested in the applicable Portfolio. The compensation amount is typically determined by multiplying a specified annual percentage rate by the average net assets held in that Portfolio for the variable annuity contracts and variable life insurance policies issued by us that offer that particular Portfolio. Currently, the maximum percentage rate we receive for any Portfolio offered under this contract is 0.20%. Some advisors

may pay us less; some do not pay us any such compensation.

The compensation we receive is paid by the advisor or its affiliate out of profits which may include fees the advisor deducted from fund assets or from the advisor’s (or its affiliate’s) other sources of revenue. You will bear the costs of these fees indirectly through your investment in the Sub-accounts that invest in these Portfolios. You may obtain a list of such fees that we receive by contacting us at our Home Office. The compensation that we receive may be significant and we may profit from this compensation.

When determining which Portfolios to offer in our variable contracts, we consider the Portfolios’ name recognition, investment objective, performance, and reputation. We also consider the amount of compensation that we receive from the Portfolios, their advisors, or their distributors. We review our Portfolios periodically. Based upon our review, we may remove or restrict allocation of additional Purchase Payments and/or transfers of contract value to a Portfolio if the Portfolio no longer meets one or more of the criteria. We do not recommend any particular Portfolio, and we do not provide investment advice.

Although the compensation we receive may be used indirectly for distribution of the contracts, compensation for selling the contracts is set by Symetra Life and paid directly by us to the broker-dealer selling you this contract. See “Section 9 - Other Information - Distribution (Principal Underwriter)” for information regarding the selling compensation we pay for sales of the contracts.

VOTING RIGHTS

Symetra Life is the legal owner of the Portfolios’ shares. However, when a Portfolio solicits proxies in connection with a shareholder vote, we are required to ask you for instructions as to how to vote those shares. The Portfolio shares are voted in accordance with the instructions we receive from you. We vote Portfolio shares for which no timely instructions are received in proportion to the voting instructions that are received with respect to that Portfolio. For this reason, a small number of contract Owners may control the outcome of a vote. Should we determine that we are no longer required to comply with the above, we will vote the shares in our own right.

TRANSFERS

During the Accumulation Phase you can transfer money among the Sub-accounts 12 times per Contract Year free of a transfer charge. We measure a Contract Year from the anniversary of your Contract Date. Each additional transfer in a Contract Year may have a charge of $10 or 2% of the amount transferred whichever is less.

The minimum amount you can transfer out of any Sub-account at one time is $500, or the entire value of the investment option if less. If a transfer will result in the remaining balance in a Sub-account being less than $500, you must transfer the entire amount out of the Sub-account. The minimum you can transfer into any Sub-account is $50.

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TRANSFER TRANSACTIONS AVAILABLE

We may accept transfers by signed written request or at our discretion, by telephone, or, if available, electronically by the Internet. Each transfer must identify:

• your contract;

• the amount of the transfer; and

• which Sub-accounts are affected.

We cannot process your transfer request until we have received the request at our Home Office. Transfer requests received by us with all information we need to process the request will be effective and valued as of the next close of the NYSE. This is usually 4:00 p.m. Eastern Time. If for any reason the NYSE is closed when we receive your transfer request, it will be valued as of the close of the NYSE on its next regular Business Day.

Transfers by telephone will be accepted if we have properly signed authorization on record. You may authorize someone else to make transfers by telephone on your behalf. Transfers by Internet will be accepted if you provide us with certain identification information, including a personal identification number (“PIN”). However, we do not accept transfer requests sent by e-mail. Transfer instructions you send electronically through the Internet are considered to be received by us at the time and date stated on the electronic acknowledgement we return to you. If you do not receive an electronic acknowledgement, you should telephone us as soon as possible.

Although we use reasonable procedures, including recording all telephone instructions and requiring certain personal information to prevent unauthorized account access, we cannot assure you that telephone or Internet activity will be completely secure or free of delays or malfunctions. If you choose to make transfers by telephone or Internet, you must be willing to assume the risk of loss that may occur despite our reasonable efforts to verify identity. We are not responsible for the negligence or wrongful acts of third parties.

We cannot guarantee that telephone transactions will always be available. For example, our offices may be closed during severe weather emergencies, or there may be interruptions in telephone service beyond our control. Moreover, if the volume of calls is unusually high, we may not have someone immediately available to receive your order.

Likewise, we cannot guarantee that online transactions processed via the Internet will always be possible. Telephone and computer systems, whether yours, your Internet service provider’s, your registered representative’s, or Symetra Life’s, can experience outages or slowdowns for a variety of reasons. These outages or slowdowns may prevent or delay our receipt of your request.

You also should protect your PIN because self-service options will be available to anyone who provides your PIN. We will not be able to verify that the person using your PIN and providing instructions is you or a person authorized by you.

SCHEDULED TRANSFERS

During the Accumulation Phase, you can choose among several investment strategies that are available at no charge. We refer to any transfer made using these strategies as “scheduled transfers” and they will not count against your 12 free transfers. We may impose restrictions on the number of scheduled transfers that can be initiated during each Contract Year or on the Sub-accounts available for scheduled transfers. If such restriction is imposed or we change the Sub-accounts available, we will notify you in writing. Once started, dollar cost averaging and appreciation sweep scheduled transfers will continue until you instruct us to stop or all money has been transferred out of the Sub-account designated as the source of the scheduled transfer. If you make a transfer or withdrawal outside of either the dollar cost averaging or appreciation sweep strategy and that transfer or withdrawal is from the Sub-account you have designated as the source for these strategies, your scheduled transfers will stop. You can restart dollar cost averaging or appreciation or interest sweep by contacting us.

Dollar Cost Averaging.  This strategy is designed to achieve a lower average cost per unit over time. It does not assure a profit or protect against a loss. Investing should continue at a consistent level in both market ups and downs. You can systematically transfer set amounts of at least $500 each month or quarter from any Sub-account to any of the other Sub-accounts. If you choose to transfer amounts among more than one Sub-account, transfers into each Sub-account must be at least $50. If a transfer will result in the remaining balance in a Sub-account being less than $500, you must transfer the entire amount out of the Sub-account.

Appreciation Sweep.  If your balance in the Fidelity VIP Money Market Portfolio is at least $10,000, you can instruct us to automatically transfer the appreciation, if any, of the Fidelity VIP Money Market Portfolio to the other Sub-accounts monthly, quarterly, semi-annually, or annually. Appreciation sweep cannot be used to transfer money to the Fidelity VIP Money Market Portfolio.

Sub-account (“Portfolio”) Rebalancing.  After your money has been invested, the investment performance of the Sub-accounts may cause the percentage in each Sub-account to change from your original allocations. If your Contract Value is at least $10,000, you can instruct us to adjust your investment in the Sub-accounts, on a quarterly, semiannual, or annual basis, to maintain a predetermined percentage allocation of Contract Value among the Sub-Accounts (“portfolio rebalancing”). Sub-account rebalancing can be used with dollar cost averaging or appreciation sweep.

LIMITS ON EXCESSIVE TRANSFERS AND MARKET TIMING ACTIVITY

Effects of Excessive Transfers and Market Timing Activity.  The contract and the Portfolios are not designed for excessive short term trading or professional market timing, or for organizations or other persons that make large, or frequent

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transfers. Frequent transfers between and among the Sub-accounts may be disruptive to Portfolio management strategies by causing forced and unplanned Portfolio turnover, and increased trading and transaction costs. In addition, these activities may require a Portfolio to maintain liquid assets rather than investing them for growth, resulting in lost opportunity costs that must be indirectly borne by contract owners. These disruptive activities may increase expenses and adversely affect Portfolio performance, thereby negatively impacting long-term contract owners.

Detection and Deterrence.  Symetra Life discourages and does not accommodate frequent transfers or market timing activity. Due to the potential adverse consequences to contract Owners, Portfolios, Portfolio shareholders, and the Separate Account, we have established certain policies and procedures to aid us in detecting and deterring contract Owners that may be engaging in frequent trading and/or market timing activities. These policies and procedures may restrict or eliminate the right to make transfers among Sub-accounts if such trades are executed by you, a market timing firm or other third party authorized to initiate transfers or exchange transactions on your behalf.

In general, our market timing procedures detect market timing by identifying transfer activity in which the transfers exceed a certain dollar amount and a certain number of transfers involving the same Sub-accounts within a specific time period. We regularly review transaction reports in an attempt to identify transfers that exceed our established parameters. We do not include Symetra Life approved investment strategies such as dollar cost averaging, Sub-account rebalancing, and other approved systematic transactions, such as asset allocation programs, when monitoring for market timing.

In general, we monitor for “roundtrip” transfers of the same Sub-account within a thirty-day period. We also monitor for “inter-Sub-account” transfers between any two Sub-accounts within a sixty-day period. The following transactions will generally be reviewed for market timing activity:

• Any two roundtrip transfers in any rolling ninety-day period; and

• Any four inter-Sub-account transfers occurring within a sixty-day period.

We will particularly scrutinize transactions involving those Sub-accounts that are subject to abuse by market timing strategies, such as those Sub-accounts that have an international investment profile. For example, if you transfer from Vanguard VIF - International Portfolio to Fidelity VIP Money Market Portfolio followed by a transfer from Fidelity VIP Money Market Portfolio to Vanguard VIF - International Portfolio within ten Business Days, we may conclude that you are engaging in market timing. We may aggregate transfers made in two or more contracts that we believe are connected in applying the procedures we employ to deter market timing.

In addition, our procedures include reviewing trading volumes every day in each Sub-account offered in your contract. We will note large or unusual trading volumes and determine if a pattern

of frequent transfers is being made in particular Sub-accounts by particular contract Owners.

If we conclude that market timing or other disruptive trading patterns are being transacted by you, we will limit you to one transfer in each 30-day period starting from the date of the transfer that we determined was a market timing transfer and continuing for six months thereafter. If, after the six-month limitation is lifted, the market timing activity resumes, we will limit you to one transfer in each 30-day period starting from the date of the transfer that we determined was a market timing transfer and continuing for twelve months thereafter. In addition, we will require you to submit transfer requests via U.S. mail during that twelve month period. If transfer instructions are inadvertently accepted from you after you have been identified as a market timer, we will reverse the transaction within one to two Business Days.

In our sole discretion, we may revise our procedures at any time without prior notice to better detect and deter market timing or other disruptive trading to comply with regulatory requirements and/or to impose additional or alternate restrictions such as imposing dollar or percentage limits on transfers or requiring transfers be submitted via U.S. mail. If we modify our procedures, they will be applied uniformly to all contract Owners and owners of other Symetra Life variable products.

If a transfer request is rejected or your transfer privileges have been restricted for any reason, we will attempt to inform you or your authorized agent by phone the next Business Day. If we do not succeed in reaching you or your authorized agent by phone, we will send a letter to your address of record. Our policies regarding transfer restrictions and rejections are applied uniformly, and we do not make exceptions for particular contract Owners.

We will use our best efforts to prevent market timing and other abusive trading practices, but the determination of whether market timing is occurring is subjective. We may not be able to detect all market timers or short term traders, and we may not be able to prevent transfers by those we do detect. In addition, the terms of the contract may also limit our ability to restrict or deter harmful transfers. If we are unable to detect or prevent market timing, the effect of such market timing may result in additional transaction costs for the Portfolios and dilution of long-term Portfolio returns. Thus, your Contract Value may be lower due to lower returns in your Sub-account investments.

Underlying Portfolio Frequent Trading Policies.  The Portfolio managers to whom we submit purchase and redemption orders may also detect large or unusual patterns of trades submitted by us on behalf of all our variable annuity contract owners and variable life policy owners. Those Portfolio managers may require us to investigate whether any of our contract Owners are engaged in market timing or other similar activity and to cooperate with them to discourage such activity. If the Portfolio managers believe you are engaged in market timing activity they may block you from making transfers or purchases to their Portfolios. In addition, federal regulations

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may require us to provide individual transaction and contract owner information to the Portfolio managers when requested.

The Portfolios to whom we submit purchase and redemption orders may adopt unique policies and procedures designed to deter excessive trading or market timing. Those policies and procedures, when applicable, are described in the prospectuses for each of the Portfolios available for investment by you. We have entered into a written agreement, as required by SEC regulation, with each underlying Portfolio or its principal underwriter. These agreements obligate us to promptly provide to the underlying Portfolio upon request certain information about the trading activity of individual contract owners. The Portfolios may require us to execute their instructions to restrict or prohibit further purchases or transfers by specific contract owners who violate the frequent trading policies established by the underlying Portfolio.

In cases of large or frequent transfers, the Portfolio managers or Symetra Life may reject trades that are determined to be detrimental to other Portfolio shareholders or violate the Portfolios’ policies and procedures. Therefore, we reserve the right to reject, without prior notice, any transfer request to a Sub-account that invests in the Portfolio if the Portfolio manager rejects such trade or the trade violates a Portfolio’s policies and procedures. If a Portfolio refuses to accept a transfer request we have already processed, we will reverse the transaction within one to two Business Days. We will notify you or your authorized agent in writing or by phone if your transfer has been rejected or reversed. We further reserve the right to implement, administer, and charge you for any fee or restriction, including redemption fees, imposed by any underlying Portfolio. Redemption fees, transfer limits, and other procedures or restrictions may be more or less successful than ours in deterring market timing or other disruptive trading and in preventing or limiting harm from such trading. You should read the prospectus of each Portfolio for more information about its ability to refuse or restrict purchases or redemptions of its shares and to impose redemption fees.

Omnibus Order.  Contract Owners and other persons with material rights under the contracts also should be aware that the purchase and redemption orders received by the underlying Portfolios generally are “omnibus” orders from intermediaries such as retirement plans and separate accounts funding variable contracts. The omnibus orders reflect the aggregation and netting of multiple orders from individual retirement plan participants and individual owners of variable contracts. The omnibus nature of these orders may limit the underlying Portfolios’ ability to apply their respective frequent trading policies and procedures. We cannot guarantee that the underlying Portfolios will not be harmed by transfer activity relating to the retirement plans or other insurance companies that may invest in the underlying 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 frequent transfer activity, it will affect other owners of underlying Portfolio shares, as well as the owners of all of the variable annuity

contracts (or variable life policies), including ours, whose variable investment options correspond to the affected underlying Portfolios. In addition, if an underlying Portfolio believes that an omnibus order we submit may reflect one or more transfer requests from Owners engaged in frequent transfer activity, the underlying Portfolio may reject the entire omnibus order and thereby delay or prevent us from implementing your request. If an underlying Portfolio rejects an omnibus order, we will notify you of the actions taken that affect your request.

5. CHARGES AND EXPENSES

There are charges and other expenses associated with the contract that reduce the return on your investment in the contract. These charges and expenses are:

INSURANCE CHARGES

Each day we make deductions for our insurance charges. We do this as part of our calculation of the value of Accumulation and Annuity Units. Insurance charges include the mortality and expense risk charge and the asset-related administration charge described below.

Mortality and Expense Risk Charge.  The mortality and expense risk charge is equal, on an annual basis, to 0.95% of the average daily net assets of each Sub-account. This charge compensates us for the mortality and expense risks we have under all Focus contracts. Our mortality risk arises from our obligations to make annuity payments for the life of the Annuitant and to pay death benefits prior to the Annuity Date. Our expense risks under the contracts include the risk that the current charges will not be sufficient in the future to cover the cost of administering the contract. If the charges under the contract are not sufficient, then we will bear the loss. If the charges are more than sufficient, we will retain the excess and may use it for any purpose, including additional distribution expenses. The rate of the mortality and expense risk charge will not be increased for the life of the contract.

Asset-Related Administration Charge.  The asset-related administration charge is based on your Contract Value at the start of each Contract Year. Over time, your Contract Value may fluctuate up and down and therefore, the asset-related administration charge may vary each Contract Year. The maximum charge is equal, on an annual basis, to 0.40% of the average daily net assets of each Sub-account, and declines as shown in the schedule below.

Contract Value	Charge
$0 to $99,999.99	0.40%
$100,000.00 to $249,999.99	0.35%
$250,000.00 to $499,999.99	0.25%
$500,000.00 to $999,999.99	0.15%
$1 million or more	0.05%

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Since this charge is an asset-based charge, the amount of the charge associated with your particular contract may have no relationship to the administrative costs actually incurred. This charge, together with the annual administration maintenance charge (see below), is for all the expenses associated with contract administration. Some of these expenses are: preparation of the contract; confirmations and statements; maintenance of contract records; personnel costs; legal and accounting fees; filing fees; and computer and system costs. If this charge and the annual administration maintenance charge are not enough to cover the costs of the contract in the future, we will bear the loss. The rates in the asset-related administration charge schedule shown above will not be changed for the life of the contract.

OPTIONAL BENEFIT CHARGES

If available in your state, you may elect optional benefits which require an additional charge. The optional benefits available are the Guaranteed Minimum Death Benefit Age Extension rider (“GMDB - Age Extension Rider”), and the Guaranteed Long Life Benefit rider (“GLLB Rider”).

GMDB - Age Extension Rider:  If you elect this rider, we will deduct an additional daily charge which is equal, on an annual basis, to 0.10% of the average daily net assets of each Sub-account. We do this as part of our calculation of the value of Accumulation Units. The charge is for the cost and risk associated with offering the GMDB- Age Extension Rider.

GLLB Rider:  If you elect this rider, we will deduct an additional charge on each of the first ten contract anniversaries. The charge is deducted from the Contract Value in proportion to the amount invested in each Sub-account on that contract anniversary. This charge reduces your contract’s death benefits.

If you surrender or annuitize your contract, we do not deduct an additional pro-rated charge. The charge will vary by contract and the charge that applies to you is shown in your contract. Once your contract is issued with the GLLB Rider, the GLLB Rider cannot be cancelled.

We determine the charge by first determining the rate as a percentage of the Purchase Payments that you tell us you will invest in the contract during the first Contract Year. This rate is based upon the age (and sex for non-qualified contracts) of the Long Life Benefit Annuitant, the deferral period chosen (which is the period between when the contract is issued and when Long Life Benefit Payments begin), the Long Life Benefit Payment amount, the amount of first year Purchase Payments, and current interest rates and mortality tables. Once the rate is determined it is multiplied by the first year Purchase Payments to determine the charge that will be deducted from the Contract Value on each of the first ten contract anniversaries. The GLLB Rider charges collected during the first 10 Contract Years may exceed the Long Life Benefit Payments actually paid out. Once the charge is determined for your contract, it will not change

other than as described below. The charge is for the cost and risk associated with offering the GLLB Rider.

Example:  Assume you are a 65-year old male with first year expected Purchase Payments totaling $200,000, requesting a Long Life Benefit Payment of $2,000 per month with a deferral period of 15 years. Based on the then current mortality and interest rate tables in effect, we determine that the annual charge rate for a 65-year old male who elects Long Life Benefit Payments starting at age 80 is 3.36% of the first year Purchase Payments. Therefore, in order to provide you with a monthly payment of $2,000, the annual rider charge assessed against your contract for the first 10 Contract Years is equal to $6,720 (3.36% multiplied by $200,000). For the charge shown, the Long Life Benefit Annuitant that was age 65 when he elected the rider would need to live to age 83 in order to recoup the charges paid.

The charge will never exceed 5% of the Purchase Payments made to your contract in the first Contract Year. In order to ensure that you do not exceed this maximum, we will monitor the Purchase Payments you make during the first Contract Year to determine if they equal or exceed the Purchase Payments you told us you would invest when the contract was issued. Then, prior to your first contract anniversary, we will calculate the amount of Purchase Payments received to date and determine if the GLLB Rider charge to be assessed on your contract anniversary exceeds 5% of the invested amount. If we determine that the charge exceeds 5% of the Purchase Payments you have made to date, we will provide written notice to you indicating the additional Purchase Payments needed so your charge does not exceed the 5% maximum. (For this purpose, we will waive the $10,000 minimum Purchase Payment requirement in order to allow you to make such additional Purchase Payments.) We will also provide the amount of the recalculated Long Life Benefit Payments if you choose not to make additional Purchase Payments to your contract. Written notice will be given 60 days prior to your contract anniversary. You will have until your first contract anniversary to make additional Purchase Payments to your contract or your Long Life Benefit Payments will be reduced. If you do not respond to our notice or you choose not to make additional Purchase Payments, your Long Life Benefit Payments will automatically be reduced on a permanent basis. We will send you a new contract data page reflecting the new GLLB Rider charge and Long Life Benefit Payment amount.

Maximum Charge Example 1:  Assume you are a 65-year old male, requesting a Long Life Benefit Payment of $2,000 per month with a deferral period of 15 years. The annual rider charge is determined to be $6,720 as described above. Prior to your contract anniversary, we determined that you have made $250,000 in Purchase Payments to your contract. Because the rider charge of $6,720 does not exceed 5% of $250,000 ($12,500), you will not need to make additional Purchase Payments to

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your contract and we will deduct the $6,720 rider charge on the first contract anniversary. Please note that although the $6,720 GLLB Rider charge does not exceed 5% of first year Purchase Payments, the percentage of first year Purchase Payments that the GLLB Rider charge equals is now 2.69% ($6,720 divided by $250,000) not 3.36% as shown in the Example above. In other words, once the GLLB Rider charge is set when the contract is issued, the dollar amount of the charge will not change (other than to assure that you do not exceed the 5% maximum charge), but the percentage rate may change if you contribute more or less than the amount of first year Purchase Payments shown on your original application for the contract. We will provide you with an updated contract data page on your first contract anniversary showing you the actual GLLB Rider charge percentage rate that your charge equals based on the actual amount of first year Purchase Payments received for your contract.

Maximum Charge Example 2:  Assume you are a 65-year old male, requesting a Long Life Benefit Payment of $2,000 per month with a deferral period of 15 years. The annual rider charge is determined to be $6,720 as described above. Assume that 60 days prior to the contract anniversary, we determine that $100,000 in Purchase Payments have been made to your contract. We calculate the maximum charge for your contract to be $5,000 (5% of $100,000). Because the rider charge of $6,720 exceeds $5,000, we will notify you of the need for additional Purchase Payments in order for you to retain the Long Life Benefit Payments that you elected when we issued the contract. In this example, you will need to make a Purchase Payment in the amount of $34,400 to reach the 5% maximum. We determine this by taking the current rider charge of $6,720 and dividing it by 5% to get $134,400, the minimum amount of Purchase Payments needed to reach the 5% maximum. We then subtract the $100,000 in Purchase Payments already made to your contract to get $34,400 ($134,400 minus $100,000). If on your contract anniversary, the amount of Purchase Payments received does not equal $134,400, we will recalculate your Long Life Benefit Payments so that the charge does not exceed 5% of the first contract year Purchase Payments. We will send you a new contract data page reflecting the new GLLB Rider charge and Long Life Benefit Payment amount.

Before electing any optional benefit, you should consult your financial advisor to help you consider the costs, benefits and risks of the benefit option for your particular circumstances. You or your registered representative may call us for a current quote regarding the GLLB Rider charge that applies to you.

ANNUAL ADMINISTRATION MAINTENANCE CHARGE

Currently during the Accumulation Phase, we deduct a $40 annual administration maintenance charge from your contract on the last day of each Contract Year and if you withdraw the entire Contract Value. This charge is deducted from your

Sub-account allocations as described in your contract. The charge will never be greater than $50. We will not deduct this charge if your Contract Value is at least $50,000 when the deduction is to be made.

SURRENDER CHARGE

A surrender charge may be assessed on withdrawals, including partial withdrawals, in excess of your free withdrawal amount that is described below. This charge is for expenses incurred in connection with the promotion, sale, and distribution of the contracts. If the surrender charge is insufficient, excess amounts resulting from the mortality and expense risk charge and other charges may be used to recover these expenses.

The contract bases the surrender charge on the length of time each Purchase Payment is in your contract. Each Purchase Payment begins a new surrender charge period. The surrender charge is stated as a percentage of the amount withdrawn, including the amount deducted for the surrender charge. It starts at 7% and declines as follows:

Complete Years Elapsed Since Purchase Payment Received	0	1	2	3	4	5	6	7
Surrender Charge (as a % of Purchase Payment Withdrawn)	7%	7%	7%	6%	6%	5%	4%	0%

Unless you tell us otherwise, when the withdrawal is for only part of the value of your contract, the surrender charge is deducted from the withdrawal amount prior to us making a payment to you. For the purpose of calculating the charge, we treat Purchase Payments as being withdrawn on a first-in, first-out basis meaning the oldest Purchase Payment is considered to be withdrawn first, the next oldest Purchase Payment is considered to be withdrawn next, and so on. See Appendix A for an example of how the surrender charge is applied.

We will not assess the surrender charge for:

• annuity payments;

• repetitive withdrawals taken over life expectancy;

• eligible healthcare confinement withdrawals;

• death benefits; and

• premium taxes.

We may reduce or eliminate the amount of the surrender charge when the contract is sold under other circumstances which reduce our sales expense. See “Section 10 - Other Information.”

FREE WITHDRAWAL AMOUNT

Your contract has a free withdrawal amount. There is no surrender charge on the first 10% of your Contract Value withdrawn in a Contract Year. We determine whether you have withdrawn more than 10% of the Contract Value at the time of

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surrender. If you take more than one withdrawal in a Contract Year, the previous withdrawals in the Contract Year are added to the current Contract Value to determine whether more than 10% of the Contract Value has been withdrawn in that Contract Year. In addition, there is no withdrawal charge on the first withdrawal you make in a Contract Year, but the surrender charge may apply.

WAIVER OF SURRENDER CHARGES UPON HEALTHCARE CONFINEMENT

If approved in your state, there is no surrender charge on withdrawals you make while you are confined in an eligible healthcare facility or within 60 days after your release. In order to be eligible for this waiver, we must receive proof that your confinement has continued for 30 or more consecutive days and that your confinement began after your Contract Date. If you are confined to a healthcare facility on the Contract Date, you are not eligible for this waiver of surrender changes until after the first Contract Year. Please see your contract for more information.

WITHDRAWAL CHARGE

We will deduct a separate withdrawal charge equal to $25 after the first withdrawal in a Contract Year unless the withdrawal is taken through electronic funds transfer (EFT). Unless you tell us otherwise, this charge is deducted from the remaining value in your contract.

We will not deduct this charge for annuity payments, repetitive withdrawals, or if you withdraw the entire Contract Value. See “Section 7 - Access To Your Money” for a discussion of repetitive withdrawals.

TRANSFER CHARGE

You can make 12 free transfers every Contract Year. If you make more than 12 transfers in a Contract Year, we will deduct a transfer charge equal to $10 or 2% of the amount that is transferred whichever is less. The transfer charge is deducted from the Sub-account that you transfer your funds from. If you transfer the entire balance from an investment option, the transfer fee is deducted from the amount transferred.

If the transfer is part of dollar cost averaging, appreciation sweep, Sub-account rebalancing, or Symetra Life approved asset allocation programs, it will not be counted as part of your 12 free transfers.

PREMIUM TAXES

States and other governmental entities (e.g., municipalities) may charge premium taxes. These taxes generally range from 0% to 3.5%, depending on the state, and are subject to change. Some states charge for these taxes at the time each Purchase Payment is made. In this case, Purchase Payments, as discussed in this prospectus, may reflect a deduction for the premium tax. Other states charge for these taxes when annuity payments begin. We may make a deduction from your contract for the payment of the premium taxes assessed in connection with your contract as stated in your contract.

INCOME OR OTHER TAXES

Currently we do not pay income or other taxes on earnings attributable to your contract. However, if we ever incur such taxes, we reserve the right to deduct them from your contract. If we choose to deduct these income or other taxes, we will notify you in writing.

PORTFOLIO EXPENSES

There are deductions from and expenses paid out of the assets of the various Portfolios for investment management fees and other operating expenses the Portfolios incur. These expenses are summarized in the fee table of the Portfolio prospectuses. For more detailed information, you should refer to the Portfolio prospectuses.

6. TAXES

This section and additional information in the SAI discuss how federal income tax applies to annuities in general. This information is not complete and is not intended as tax advice. Tax laws and their interpretations are complex and subject to change. No attempt is made to discuss state or other tax laws. Symetra Life does not guarantee the tax treatment of any contract or any transaction involving a contract. You should consult a competent tax advisor about your individual circumstances.

ANNUITY CONTRACTS IN GENERAL

Under the Code, you generally do not pay tax on contract earnings until received. Different tax rules apply to Purchase Payments and distributions depending on how you take money out and whether your contract is qualified or non-qualified.

Earnings for corporate owned contracts and other contracts not owned for the benefit of natural persons are generally taxed as ordinary income in the current year. Exceptions may apply. For example, contracts by a trust which holds the contract as an agent for a natural person, contracts held for non-qualified deferred compensation arrangements, and contracts held for qualified retirement plans may be able to defer tax on earnings until money is withdrawn from the contract.

DEATH BENEFITS

The rules governing taxation of payments from an annuity contract, as discussed above, generally apply to the payment of death benefits and depend on whether the death benefits are paid as lump sum or annuity payments. Estate or gift taxes may also apply.

QUALIFIED CONTRACTS

Contracts purchased as an IRA, Roth IRA, SIMPLE IRA, SEP IRA, TSA, Roth TSA, 457 plan or other retirement plan, are referred to as “qualified contracts” because they are qualified under the Code to provide tax deferral for retirement purposes. You do not have to purchase an annuity contract to qualify for the tax deferral offered by these retirement plans. There may be other investment vehicles that can be purchased for your retirement plan. However, an annuity contract has features and benefits other than tax deferral that may make it an appropriate

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investment for your retirement plan. Numerous special tax rules apply to the participants in qualified plans and to contracts used in connection with qualified plans. Therefore, we make no attempt in this prospectus to provide more than general information about use of the contract with qualified plans. If the contract is purchased as part of your employer’s retirement plan, we are not responsible for determining if your employer’s plan or arrangement satisfies the requirements of the Code and/or the Employee Retirement Income Security Act of 1974 (ERISA). You should consult your tax advisor regarding these features and benefits before you buy a qualified contract.

Qualified contracts are subject to special rules and limits on Purchase Payments and distributions that vary according to the type of retirement plan. Ineligible or excess contributions to certain retirement plans can result in substantial penalties and possible loss of the contract’s or retirement plan’s qualified status. Tax penalties of 10% or more, may apply to certain distributions; for example if you are under age 59 ¹/2 and not disabled as defined by the Code.

You may be able to make a direct transfer or rollover from other qualified plans and contracts to this contract. If certain requirements are met, you may be able to transfer amounts in your contract to another eligible retirement plan or IRA.

Generally, qualified plans (except for Roth IRAs) are subject to required minimum distributions. For TSAs and 457 Plans you must begin receiving required minimum distributions no later than April 1 of the year following the latter of attainment of age 70 ¹/2 or the date you sever employment with the employer sponsoring the plan. For IRAs, you must begin receiving required minimum distributions by April 1 of the year following the year in which you reach age 70 ¹/2. There may be substantial penalties if you fail to take required minimum distributions.

Under federal tax law, IRAs and Roth IRAs both limit the amount of annual contributions an individual can contribute to his or her IRA or Roth IRA. The IRA and Roth IRA annual contribution limit for 2010 of $5,000 is lower than the minimum Purchase Payment of $10,000 that we accept. Therefore, you may only contribute Purchase Payments that are rollover contributions of $10,000 or more from other eligible retirement plans. A rollover from or conversion of an IRA to a Roth IRA is generally subject to tax. A special rule permits taxation of Roth IRA conversions made during the 2010 tax year to be split between 2011 and 2012. You may wish to consult a tax advisor before combining any converted amounts with any other Roth IRA contributions, including any other conversion amounts from other tax years.

Furthermore, under final regulations issued by the Internal Revenue Service (“IRS”), the actuarial present value of “other benefits” provided under annuity contracts are included for purposes of calculating required minimum distributions. These other benefits include the value of any guaranteed minimum death benefits provided under your contract or the value of optional benefits, such as the Long Life Benefit under the GLLB Rider. These benefits will be considered in calculating

required minimum distributions and do impact the amount of your required minimum distribution. If you are purchasing a qualified contract, you should consult a tax advisor.

To the extent Purchase Payments have a zero cost basis (were made with pre-tax dollars), distributions will be taxed as ordinary income. Under some circumstances, you may be able to make “after-tax” Purchase Payments. In some cases, you must satisfy retirement plan or Code requirements before you take money out. For example, the Code restricts certain withdrawals from TSAs.

When this contract is issued in connection with a qualified plan, we will amend the contract as necessary to conform to the requirements of the plan. However, you are cautioned that the rights of any person to benefits under the retirement plan may be subject to the terms and conditions of the plans, regardless of the terms and conditions of the contract. In addition, we will not be bound by the terms and conditions of a retirement plan to the extent such terms and conditions contradict the contract, unless we consent.

The taxation of the additional benefits provided by the riders offered in this contract is complex. The IRS may disagree with the tax treatment generally described here, or the IRS may issue additional guidance regarding the taxation of these types of rider. Such IRS actions may result in adverse tax consequences for you or additional tax liability. You should consult your tax advisor prior to selecting any optional benefit rider under the contract.

If the GLLB Rider is issued with a qualified contract, the Owner must be the Annuitant under the contract, the Long Life Benefit Annuitant under the GLLB Rider, and the Payee. The entire interest in a qualified contract must be distributed in accordance with minimum distribution requirements that are imposed under federal income tax law. Under these requirements, the entire interest in the contract generally must be distributed at least as rapidly as over the life or life expectancy of the Owner, or the joint lives or joint life expectancy of the Owner and his or her designated beneficiary, commencing no later than April 1 of the calendar year following the calendar year in which the Owner attains age 70 ¹/2 (the “required beginning date”). These requirements do not apply to a Roth IRA during the Owner’s life. Also, the minimum distribution requirements include certain rules regarding the distribution of any remaining interest in a qualified contract, including a Roth IRA, that apply after the death of the Owner.

If necessary, required minimum distributions may be taken in the form of withdrawals from (1) the Contract Value prior to the contract’s Annuity Date, (2) the GLLB Rider prior to the Long Life Benefit Commencement Date if the Contract Value is reduced to zero or if the contract has passed its Annuity Date, or (3) from another IRA, Roth IRA, SIMPLE IRA, or SEP IRA that you own, to the extent permitted under federal tax law. If the required beginning date is prior to the Long Life Benefit Commencement Date under the GLLB Rider, the required

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minimum distribution must be determined prior to the Long Life Benefit Commencement Date by taking into account the actuarial present value of the Long Life Benefit. Any distributions from the GLLB Rider prior to the Long Life Benefit Commencement Date will result in a recalculation of and reduction in the Long Life Benefit. It is possible that required minimum distributions can result in the Long Life Benefit Payments being significantly reduced. This means that you could pay all ten GLLB Rider charges and receive lower Long Life Benefit Payments than those originally provided when your contract was issued.

Annuity payments under a qualified contract and Long Life Benefit Payments under the GLLB Rider must be paid in a manner that satisfies the minimum distribution requirements. It is unclear whether these requirements apply by treating the annuity payments and the Long Life Benefit Payments as separate streams of annuity payments, or as a single stream of annuity payments. We will treat the annuity payments and the Long Life Benefit Payments as separate streams of annuity payments for purposes of these requirements. However, the IRS could take a different view.

If the annuity payments and Long Life Benefit Payments are treated as separate streams of annuity payments for this purpose, these payments could fail to satisfy the minimum distribution requirements in certain circumstances, e.g., generally when annuity payments are paid on different dates and in different intervals than the Long Life Benefit Payments, and when the Annuity Date under the contract is prior to the Long Life Benefit Commencement Date under the GLLB Rider. If annuity payments and/or Long Life Benefit Payments fail to satisfy the minimum distribution requirements, the Owner will be subject to an excise tax each equal to 50 percent of the amount by which the amount of the required minimum distribution for a calendar year exceeds the amount of the aggregate distributions for the year with respect to the contract and GLLB Rider. In addition, the contract and rider could fail to qualify as an IRA, Roth IRA, SIMPLE IRA, or SEP IRA contract, resulting in adverse income tax consequences to the Owner.

Before purchasing a qualified contract with a GLLB Rider, the Owner should consult a tax advisor about the application of the minimum distribution requirements to the contract and the rider.

TAX SHELTERED ANNUITIES - 403(B) CONTRACTS

Tax Sheltered Annuities (“TSAs”) are available to eligible employees of public school systems and organizations that are tax exempt under Section 501(c)(3) of the Code. Effective on January 1, 2009, Department of Treasury 403(b) regulations went into effect. The regulations generally require employers offering 403(b) plans to maintain those plans pursuant to a written plan document and to coordinate administration of the plans. Depending on the employer’s written plan, there may be restrictions on the availability of loans, distributions, transfers and exchanges.

TSAs under Section 403(b) of the Code allow employees of certain Section 501(c)(3) organizations and public schools to exclude from their gross income the payments made, within certain limits, on a contract that will provide an annuity for the employee’s retirement. These payments may be subject to FICA (social security) tax. Distributions of (1) salary reduction contributions made in years beginning after December 31, 1988; (2) earnings on those contributions; and (3) earnings on amounts held as of the last year beginning before January 1, 1989, are not allowed prior to age 59 ¹/2, severance from employment, death or disability. Salary reduction contributions may also be distributed upon hardship, but would generally be subject to penalties. Distributions of employer contributions from contracts issued on or after January 1, 2009, are subject to distribution restrictions specified in the employer’s 403(b) plan.

If your contract is issued pursuant to a 403(b) plan, we generally are required to confirm with your 403(b) plan sponsor that your Purchase Payments to or surrender, withdrawals, transfers or loans from your contract comply with applicable tax requirements before we process those transactions and to decline Purchase Payments or requests that are not in compliance. These transactions cannot be processed until all information required under the tax law is received. By directing Purchase Payments to the Contract or requesting any one of these payments, you consent to the sharing of confidential information about you, the contract, and any other 403(b) contracts or accounts you have under the 403(b) plan among us, your employer or plan sponsor, any plan administrator or recordkeeper, and other product providers.

As a general matter, all contracts that have received plan contributions after 2004 are required to be included in the 403(b) and subject to your employer’s administration. The rules are complex, and this discussion is not intended as tax advice. The IRS continues to issue guidance and clarification regarding the rules. Some rules may be subject to difference interpretations. You should consult your own tax advisor or your employer to discuss the regulations.

WITHDRAWALS FROM ROTH IRAS AND ROTH TSAS

Qualified distributions from Roth IRA and Roth TSA annuities are entirely federal income tax free. A qualified distribution requires that the individual has held the Roth IRA or Roth TSA for at least five years and, in addition, that the distribution is made after the individual reaches age 59 ¹/2, on account of the individual’s death or disability, or, for Roth IRAs only, as a qualified first-time home purchase, subject to $10,000 lifetime maximum, for the individual, or for a spouse, child, grandchild, or ancestor.

WITHDRAWALS FOR INVESTMENT ADVISOR FEES

Withdrawals from non-qualified contracts for the payment of investment advisor fees will be considered taxable distributions from the contract. The IRS has held, however, that the payment of investment advisor fees from a tax-qualified contract need not be considered a distribution for income tax purposes if certain requirements are met. You should consult a competent tax advisor for details.

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NON-QUALIFIED CONTRACTS

Contracts purchased with after-tax money and not part of an IRA, Roth IRA, SIMPLE IRA, SEP IRA, TSA, Roth TSA, 457, or other retirement plan, are referred to as non-qualified contracts and receive different tax treatment than qualified contracts. Your cost basis equals the total amount of the after-tax Purchase Payments remaining in the contract.

The Code generally treats distributions as coming first from earnings (also referred to in the internal revenue code as “income on the contract”) and then from Purchase Payments. Non-qualified deferred annuity contracts issued by the same insurer to the same Owner in the same year are treated as one contract for tax purposes. Distributions from non-qualified contracts are taxed as ordinary income to the extent they are attributable to earnings. Since you have already been taxed on the cost basis, distributions attributable to Purchase Payments are generally not taxed.

There may be a 10% tax penalty on earnings withdrawn before you reach age 59 ¹/2. Certain exceptions apply, such as death or disability as defined by the Code.

If the contract’s Income Phase occurs at a time when the Annuitant has reached an advanced age (e.g., past age 95), it is possible that the contract would not be treated as an annuity for federal income tax purposes. In that event, gains under the contract could be currently includable in your income.

TAXATION OF ANNUITY PAYMENTS

Although tax consequences may vary depending on the payout option elected under an annuity contract, a portion of each annuity payment (or “amount received as an annuity”) is generally not taxed and the remainder is taxed as ordinary income. The non-taxable portion of an annuity payment is generally determined using an exclusion ratio in a manner that is designed to allow you to recover your after-tax investment in the contract. For qualified contracts, the after-tax investment may be zero. The exclusion ratio is determined when annuity payments start. It is applied to each annuity payment over the expected stream of annuity payments, so that each annuity payment is taxable in part and tax-free in part. Once your investment in the contract has been fully recovered, however, the full amount of each annuity payment is subject to tax as ordinary income.

OPTIONAL BENEFIT RIDERS - NON-QUALIFIED CONTRACTS

We generally believe Long Life Benefit Payments will not be taxed until they are received by you.

The taxation of distributions under a contract issued with an optional benefit rider is complex and unclear in certain respects. For instance, it is unclear whether the contract and the Guaranteed Long Life Benefit Rider should be treated for federal income tax purposes as part of a single integrated contract, or as separate contracts. In addition, it is unclear in some circumstances whether annuity payments under the contract and Long Life Benefit Payments constitute amounts

received as an annuity that are taxed using an exclusion ratio as described in the “Taxation of Annuity Payments” section, or amounts not received as an annuity that are taxed to the extent of the income on the contract as described in the “Non-Qualified Contracts” section. The IRS might take a position that differs from the position we have taken on the federal income tax treatment of the contract, optional benefit riders, and benefits thereunder. You should consult your tax advisor prior to selecting any optional benefit rider under the contract.

Unless otherwise noted, and absent further guidance to the contrary, we will treat the contract and the optional benefit riders as part of a single integrated annuity contract. Also, absent further guidance, we will treat annuity payments under the contract and Long Life Benefit Payments under the GLLB Rider as amounts received as an annuity where (1) the Annuitant under the contract and the Long Life Benefit Annuitant under the GLLB Rider are the same, (2) the Annuity Date under the contract and the Long Life Benefit Commencement Date under the GLLB Rider are the same, and (3) annuity payments under the contract and Long Life Benefit Payments under the GLLB Rider are paid in the same intervals and on the same dates. However, this treatment might not be available in other circumstances.

For example, if the Annuity Date and the Long Life Benefit Commencement Date are different, we will treat amounts paid under the GLLB Rider prior to the Annuity Date as amounts not received as an annuity. If the Annuity Date is prior to the Long Life Benefit Commencement Date, we may or may not treat annuity payments made prior to the Long Life Benefit Commencement Date as amounts received as an annuity, depending on the facts and circumstances. For instance, we will treat annuity payments made prior to the Long Life Benefit Commencement Date as amounts not received as an annuity if the annuity payments can cease prior to the Long Life Benefit Commencement Date. This can occur, for example, if (1) you choose annuity payments over a fixed term that expires prior to the Long Life Benefit Commencement Date, or (2) the Annuitant and Long Life Benefit Annuitant are different people, you choose annuity payments under the contract for the life of the Annuitant, and annuity payments will cease if the Annuitant dies prior to the Long Life Benefit Commencement Date.

In addition, in order for distributions to be treated as amounts received as an annuity, they must be payable in periodic installments at regular intervals. If the annuity payments under the contract and Long Life Benefit Payments are paid in different intervals (e.g., annuity payments are made annually and Long Life Benefit Payments are made monthly) or on different dates (e.g., annuity payments are made on the first of the month, and Long Life Benefit Payments are made on the 15th of the month), we will treat the annuity payments and the Long Life Benefit Payments as amounts not received as an annuity.

We do not believe that the fees and charges associated with any optional benefit provided under the contract should be treated as

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taxable withdrawals. However, it is possible that the IRS may take the position that the fees and charges deducted for certain optional benefit riders, including the GLLB Rider, are deemed to be taxable distributions that are subject to the 10 percent penalty tax on certain distributions made before age 59 ¹/2 described in the “Non-Qualified Contracts” section. Alternatively, if the contract and GLLB Rider are treated as separate contracts for federal income tax purposes, when a distribution is made under the contract or Rider, any GLLB Rider charges deducted during the 12 months prior to the distribution could be treated as taxable withdrawals that are subject to the 10% penalty tax for the year in which the charges were deducted.

The IRS may determine that the income on the contract, and thus the taxable portion of the withdrawal, should be increased to reflect certain amounts provided under the GLLB Rider. Therefore, when you make a taxable withdrawal from the contract, you may be taxed on those additional amounts provided under the GLLB Rider in addition to any taxable portion of the withdrawal from the Contract Value.

In general, any amount actually received under the contract as a death benefit, including an optional death benefit, will be treated for tax purposes as provided in the “Non-Qualified Contracts” and “Taxation of Annuity Payments” sections.

As mentioned above, distributions prior to age 59 ¹/2 are subject to a 10% penalty tax, subject to certain exceptions. One exception is for distributions that are part of a series of substantially equal periodic payments (made not less frequently than annually) for the life (or life expectancy) of the taxpayer or the joint lives (or joint life expectancies) of the taxpayer and his or her designated beneficiary. Whether annuity payments made prior to age 59 ¹/2 satisfy this exception will depend on the manner in which such payments are made under the facts and circumstances of each case. We generally will not treat payments made prior to age 59 ¹/2 as satisfying this exception if the Annuity Date and Long Life Benefit Commencement Date are different.

EFFECT OF CIVIL UNIONS AND DOMESTIC PARTNERSHIPS

For non-qualified and qualified annuities, there may be certain distribution options or elections available under federal tax law to beneficiaries who are “spouses” as defined under federal tax law. However, these same options may not be available to surviving beneficiaries who are “civil union partners” ,“domestic partners” or other similar relationships as recognized under the laws of certain states. These options are available only to a person defined as a “spouse” under the federal Defense of Marriage Act, or any other applicable federal law. Accordingly, the administration of spousal rights and the related tax reporting for the contract will be done in a manner consistent with federal tax law requirements. The rights and benefits of civil union, domestic partnerships and other similar relationships under federal law is evolving and complex. Therefore, you should contact your legal advisor to discuss the availability of options and elections available to your surviving partner.

EXCHANGES

From time to time we may offer programs under which certain variable annuity contracts previously issued by us may be exchanged for the contracts offered by this prospectus. These programs will be made available on terms and conditions determined by us, and any such programs will comply with applicable law. We believe the exchanges will be tax free for federal income tax purposes; however, you should consult your tax advisor. Generally you can exchange one non-qualified contract for another in a tax-free exchange under Section 1035 of the Code. In addition, if your contract is a qualified contract, then it will generally qualify as a tax free rollover or transfer.

If you exchange part of an existing contract for this contract, and within 12 months of the exchange you receive a payment (e.g., you make a withdrawal) from either contract, the exchange may not be treated as a tax-free exchange. Rather, the exchange may be treated as if you had made a taxable withdrawal from the existing contract and then purchased this contract. Subject to certain exceptions, some or all of the amount exchanged into this contract could be includible in your income and subject to the 10% tax described in the “Non-Qualified Contracts” section.

If you are considering a partial exchange of an annuity contract, you should consider the conditions described by Revenue Procedure 2008-24 effective for partial exchanges completed on or after June 30, 2008. Partial exchanges may qualify for tax free treatment if you meet the conditions outlined in the revenue procedure. We advise you to consult a tax advisor as to the potential tax consequences before attempting any partial exchange.

Before making an exchange, you should compare both contracts carefully. You may have to pay a surrender charge on your existing annuity contract; other charges may be higher (or lower) and the benefits may be different. You should not exchange another variable annuity contract for this one unless you determine that, after knowing all the facts, the exchange is in your best interest. Also, you should consult your tax advisor in connection with an exchange involving the contract, especially if you may make a withdrawal from either contract within 12 months after the exchange.

A transfer or assignment of ownership of a contract, the designation of an Annuitant, the selection of certain maturity dates, or the exchange of a contract may result in certain tax consequences to you that are not discussed here. An Owner contemplating any such transfer, assignment or exchange should consult with their tax advisor.

DIVERSIFICATION/OWNERSHIP

Variable annuity contracts receive tax deferral as long as the Sub-accounts meet diversification standards set by Treasury Regulations. This favorable tax treatment allows you to select and make transfers among Sub-accounts without paying income tax until you take money out. We believe the Sub-accounts offered under the contract are being managed to comply with existing standards.

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In certain circumstances, a variable contract owner may be considered the owner of the assets of a segregated account, such as the Separate Account, if the IRS deems the owner to possess “ownership” in those assets, such as the ability to exercise investment control over the assets. Under this contract, you have the option to invest in a number of Sub-accounts. To date, neither Treasury Regulations nor the Code give specific guidance as to the circumstances under which your contract might lose its tax favored status as an annuity because of the number and type of Sub-accounts you can select from, and the extent to which you can make transfers. If issued, such guidance could be applied either prospectively or retroactively and result in you being treated as the owner of the Separate Account investments, thereby resulting in the loss of the favorable tax treatment as an annuity contract. Due to the uncertainty in this area, we reserve the right to modify the contract in an attempt to maintain favorable tax treatment. However, there is no assurance that such modifications would be successful.

TAX WITHHOLDING

Generally, federal income tax is withheld from the taxable portion of withdrawals at a rate of 10%. Withholding on periodic payments as defined by the Code is at the same rate as wages. Typically, you may elect not to have income taxes withheld or to have withholding done at a different rate. Certain “eligible rollover distributions” from 403(b) or governmental 457 plans, which are not directly rolled over to another eligible retirement plan or IRA, are subject to a mandatory 20% withholding. For this purpose, an eligible rollover distribution is any distribution to an employee from such a plan, except certain 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 TSA 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.

FEDERAL ESTATE TAXES

While no attempt is being made to discuss the federal estate tax implications of the contract, a purchaser should keep in mind that the value of an annuity contract 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 contract, the value of the annuity included in the gross estate may be the value of the lump sum payment payable to the designated beneficiary or the actuarial value of the payments to be received by the beneficiary. Consult an estate planning advisor for more information.

GENERATION-SKIPPING TRANSFER TAX

Under certain circumstances, the Code may impose a “generation skipping transfer tax” when all or part of an annuity

contract 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 contract, or from any applicable payment, and pay it directly to the IRS.

ESTATE, GIFT AND GENERATION-SKIPPING TRANSFER TAXES IN 2010

In 2001, Congress enacted the Economic Growth and Tax Relief Reconciliation Act of 2001 (“EGTRRA”), which eliminated the estate tax (but not the gift tax) and replaced it with a carryover basis income tax regime for estates of decedents dying in 2010, and also eliminated the generation-skipping transfer tax for transfers made in 2010. Beginning in 2011, however, EGTRRA allowed the estate, gift and generation-skipping transfer taxes to return to their pre-EGTRRA form. Moreover, it is possible that Congress may enact legislation reinstating the estate and generation-skipping transfer taxes for 2010, possibly on a retroactive basis. The uncertainty as to future estate, gift and generation-skipping transfer taxes underscores the importance of seeking guidance from a qualified advisor to help ensure that your estate plan adequately addresses your needs and that of your beneficiaries under all possible scenarios.

ANNUITY PURCHASES BY NONRESIDENT ALIENS AND FOREIGN CORPORATIONS

The discussion above provides general information regarding U.S. federal income tax consequences to annuity purchasers that are U.S. citizens or residents. If you are not a U.S. citizen or resident, you will generally be subject to U.S. federal withholding tax on taxable distributions from annuity contracts at a 30% rate, unless a lower treaty rate applies. In addition, you may be subject to state and/or municipal taxes and taxes that may be imposed by your country of citizenship or residence. You should consult with a qualified tax advisor regarding U.S. state, and foreign taxation with respect to an annuity contract purchase.

FOREIGN TAX CREDITS

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

POSSIBLE TAX LAW CHANGES

Although the likelihood of legislative changes is uncertain, there is always the possibility that the tax treatment of the contract could change by legislation or otherwise. Consult a tax advisor with respect to legislative developments and their effect on the contract.

We have the right to modify the contract in response to legislative changes that could otherwise diminish the favorable tax treatment that annuity contract owners currently receive. We make no guarantee regarding the tax status of any contact and do not intend the above discussion as tax advice.

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7. ACCESS TO YOUR MONEY

Under your contract, money may be accessed:

• by making partial withdrawals during the Accumulation Phase;

• surrendering your contract during the Accumulation Phase;

• by taking repetitive withdrawals;

• by receiving payments during the Income Phase (see “Section 2 - Annuity Payments”); or

• when a death benefit is paid to your Beneficiary (see “Section 9 - Death Benefit and Optional Death Benefit Rider”).

PARTIAL WITHDRAWALS

During the Accumulation Phase, you can make partial withdrawals from the amount available under your contract by writing to us at our Home Office. Partial withdrawals must be at least $500, or the Contract Value if less. Unless you tell us otherwise, partial withdrawals will be made pro rata from your Sub-account allocations. If a withdrawal would result in the remaining balance in a Sub-account being less than $500, you must transfer the entire amount out of the Sub-account. Once we receive your request, withdrawals from the Sub-accounts will be effective as of the next close of the NYSE. Partial withdrawals are payable within seven calendar days.

A withdrawal may have a surrender charge, a withdrawal charge, and, if you withdraw the entire Contract Value, an annual administration maintenance charge. An example of how the charges are applied to a withdrawal is shown in Appendix A. Unless you tell us otherwise, when the withdrawal is for only part of the value of your contract, the charges are deducted from the withdrawal amount prior to us making a payment to you. There are situations where all or some of these charges do not apply. See “Section 5 - Charges and Expenses” for a discussion of the applicable charges.

Withdrawals may be restricted or prohibited by the terms of qualified contracts.

SURRENDERING YOUR CONTRACT

You can surrender your contract for its Contract Value at any time before you begin to receive annuity payments. For a surrender to be effective, we must receive your written request at our Home Office. All benefits other than the GLLB Rider, if applicable, will terminate as of the date we receive the required information to process your surrender request. We will determine your surrender value as of the next close of the NYSE after we have received the required information to process your request. The surrender value will be equal to your Contract Value minus any applicable surrender charge, withdrawal charge, annual administration maintenance charge, and pro-rated rider charges. We will pay you the surrender value within 7 calendar days.

If you have purchased the GLLB Rider, you will still be entitled to the Long Life Benefit Payments as described in “Section 8 - Guaranteed Long Life Benefit Rider.”

REPETITIVE WITHDRAWALS

Repetitive withdrawals allow you to automatically withdraw payments of a pre-determined dollar amount or fixed percentage of Contract Value that you request from a specified Sub-account monthly, quarterly, semi-annually or annually. The minimum amount for each withdrawal is $500, or the Contract Value if less. You may request repetitive withdrawals by completing the appropriate form and sending it to our Home Office. Repetitive withdrawals may be used to avoid tax penalties for premature withdrawals or to satisfy distribution requirements of certain retirement plans. To do this they must be a series of substantially equal withdrawals made at least annually and based on:

• your life expectancy; or

• the joint life expectancy of you and a Beneficiary.

You may begin repetitive withdrawals based on life expectancy by providing us with your gender and verification of age in order for us to calculate the monthly, quarterly, or annual withdrawal amount. We calculate the amount of a repetitive withdrawal based on life expectancy by dividing the Contract Value by the life expectancy of the Owner as determined by using the IRS single life table. If it is a joint life expectancy, then we divide the Contract Value by the life expectancy of the Owner and joint Owner (or Beneficiary) by the IRS joint life table.

Example One:  Assume that the Contract Value is equal to $100,000 and the Owner requests a repetitive withdrawal and is age 55. Based on the IRS single life table, the life expectancy of an Owner age 55 is 29.6 years. The first repetitive withdrawal amount is equal to $100,000 divided by 29.6 which equals an annual payment of $3,378.38.

Example Two:  Assume that in one year, when the contract Owner is age 56, the Contract Value is equal to $101,453. The life expectancy of the Owner is 28.7 years. The repetitive withdrawal amount is equal to $101,453 divided by 28.7 which equals an annual payment of $3,534.95.

Repetitive withdrawals that are based on life expectancy may allow you to avoid the early withdrawal tax penalty of 10% that you would otherwise pay for taking withdrawals prior to age 59 ¹/2. If you take additional withdrawals or otherwise modify or stop these repetitive withdrawals, however, there may be tax consequences and penalties. You should talk to your tax advisor for more information on taking repetitive withdrawals to avoid the 10% tax penalty.

If you make repetitive withdrawals that are not based on life expectancy, the same restrictions, income taxes, and tax penalties that apply to any other withdrawals also apply to repetitive withdrawals.

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WITHDRAWAL RESTRICTIONS ON TSA CONTRACTS

Your right to make withdrawals or surrender the contract is subject to any restrictions imposed by applicable law or retirement plans.

There are certain restrictions imposed on withdrawals of contracts used as funding vehicles for TSAs under Section 403(b) of the Code. Withdrawals attributable to salary reduction contributions to TSAs for years after 1988 and any earnings accrued after 1988, cannot be taken out unless:

• you attain age 59 ¹/2;

• you leave your job;

• you die or become disabled as defined by the Code;

• you experience a qualifying hardship (applies to contributions only);

• you divorce and a distribution to your former spouse is permitted under a Qualified Domestic Relations Order; or

Also, for 403(b) contracts issued on or after January 1, 2009, amounts attributable to employer contributions are subject to restrictions on withdrawals specified in your employer’s 403(b) plan, in order to comply with tax regulations. Amounts transferred to a 403(b) contract from other 403(b) contracts or accounts are generally subject to the same restrictions on withdrawals applicable under the prior contract or account.

In the case of all qualified contracts, tax penalties may apply to withdrawals. There may also be restrictions on the form and manner in which benefits may be paid. For example, spousal consent may be needed in certain instances before a distribution may be made. However, these restrictions on withdrawals do not affect rollovers or transfers between certain retirement plans.

MINIMUM VALUE REQUIREMENTS

You must withdraw the entire amount out of an investment option if, after a withdrawal, the remaining value in the investment option would be less than $500. Similarly, you must withdraw the entire Contract Value and your contract will terminate if, after a withdrawal, the remaining Contract Value would be less than the minimum, if any, stated in your contract. However, negative investment performance alone will not cause a forced withdrawal.

Withdrawals, including any charges, reduce the number of Accumulation Units and the death benefit. Income taxes, tax penalties and certain restrictions may also apply. See “Section 6 - Taxes.”

8. OPTIONAL LIVING BENEFIT RIDERS

If approved in your state, you can elect the GLLB Rider when you purchase the contract. This rider can also be combined with the GMDB-Age Extension rider.

GUARANTEED LONG LIFE BENEFIT RIDER (“GLLB RIDER”) (PATENT PENDING)

The contract offers the GLLB Rider which guarantees that we will make Long Life Benefit Payments to the Payee if the rider is in force on the Long Life Benefit Commencement Date and the Long Life Benefit Annuitant is alive. The Long Life Benefit Payments will continue as long as the Long Life Benefit Annuitant is alive. You may only elect this rider when you purchase your contract and we will deduct an additional charge. This rider is only available for non-qualified contracts and IRA contracts. The contract may only be purchased by one Owner; we do not allow purchases by joint Owners. If the Owner is a non-natural person, then only one Annuitant may be named; we do not allow joint Annuitants.

This rider has no cash value and does not provide a death benefit. Please note that any amount that we may pay or make available under the rider is subject to our financial strength and claims-paying ability.

The GLLB Rider provides assurance that you will not outlive your income if certain conditions are met. Because it can be less expensive to buy future guaranteed income now rather than at the time when you want income payments to start, this rider may be a useful component of an overall retirement plan to protect against longevity risk. However, there are several important points to consider before purchasing the GLLB Rider:

• If the Long Life Benefit Annuitant dies prior to the Long Life Benefit Commencement Date, the rider will be terminated and we will not refund the charge that you paid. Therefore, you may be paying for a benefit that you never receive.

• Even if the Long Life Benefit Annuitant reaches the Long Life Benefit Commencement Date, the GLLB Rider charges collected during the first 10 Contract Years may exceed the Long Life Benefit Payments actually paid out. Under the GLLB Rider, we are only required to make Long Life Benefit Payments as long as the Long Life Benefit Annuitant is alive. For example, the Long Life Benefit Annuitant may die just a few months after Long Life Benefit Payments have begun. In that case, no further payments will be made and it is likely that you will have paid more in charges then you received in Long Life Benefit Payments.

• The charge varies by the age (and sex for non-qualified contracts) of the Long Life Benefit Annuitant, the amount of the Long Life Benefit Payment, the deferral period chosen, the amount of the first year Purchase Payments, and interest rate and mortality tables in effect at the time the contract is issued.

• The charge is deducted from the Contract Value. Because you may use your Contract Value to purchase annuity payments, your annuity payments may be less if you choose this rider. However, we do not reduce Long Life Benefit Payments if you choose to annuitize your contract after the 10th Contract Year.

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• The charge is treated like other charges under the contract and will reduce your contract’s death benefit. See “Section 9 - Death Benefit and Optional Death Benefit Rider” for more information.

• The Long Life Benefit Payments are separate from and in addition to any annuity payments. For tax purposes, we will treat Long Life Benefit Payments as withdrawals, which are generally taxed less favorably than annuity payments. See “Section 6 - Taxes” for more information.

• If you withdraw your entire Contract Value or annuitize your contract prior to the 10th contract anniversary, we will reduce the amount of the Long Life Benefit Payments. The reduced Long Life Benefit Payments will generally be significantly less than the originally selected Long Life Benefit Payments.

• If you withdraw your entire Contract Value or annuitize your contract after the 10th contract anniversary but before the Long Life Benefit Commencement Date, there will be no reduction in Long Life Benefit Payments. The Long Life Benefit Payments will commence on the Long Life Benefit Commencement Date.

• Once the rider is elected, it cannot be canceled.

Long Life Benefit Annuitant:  The Long Life Benefit Annuitant is the person on whose life the Long Life Benefit Payments are based. Once the Long Life Benefit Annuitant is selected, it cannot be changed. The Long Life Benefit Annuitant must be the same as the Owner. For non-natural Owners, the Long Life Benefit Annuitant must be the same as the Annuitant. At the time of election, the Long Life Benefit Annuitant must be no younger than age 50 and no older than age 75. The Owner selects the amount of each payment and a deferral period on the contract application. The Long Life Benefit Payments will begin at the end of the deferral period. We call this the Long Life Benefit Commencement Date.

Long Life Benefit Commencement Date:  The Long Life Benefit Commencement Date is the date of the first Long Life Benefit Payment and is selected by the Owner on the contract application. Once the Long Life Benefit Commencement Date is selected it cannot be changed. The time between the Contract Date and the Long Life Benefit Commencement Date is referred to as the deferral period. Deferral periods of five-year increments are allowed beginning 15 years from the Contract Date and ending 35 years from the Contract Date. The age of the Long Life Benefit Annuitant plus the deferral period chosen cannot exceed age 95.

Long Life Benefit Payments:  If the Long Life Benefit Annuitant is alive on the Long Life Benefit Commencement Date, Long Life Benefit Payments will begin. These payments will be made monthly and must be at least $500 and no more than $40,000.00. You choose the amount of the Long Life Benefit Payment when you elect this rider. The amount of the Long Life Benefit Payment cannot be changed except as described below under Reduced Long Life Benefit Payments, Adjustment to Long Life Benefit Payments for Required

Minimum Distributions, and in Section 5 - Optional Benefit Charges. Because the charge for this rider may be significant in relation to the Purchase Payments made to the contract, you should consult with your registered representative to determine the charge applicable to your desired Long Life Benefit Payment prior to choosing an amount. Over time the charge assessed for this rider may reduce your Contract Value to zero. If the Contract Value is reduced to zero or you annuitize your contract prior to the 10th contract anniversary, we will reduce the amount of the Long Life Benefit Payments as described below in the Reduced Long Life Benefit Payments section. The Long Life Benefit Payments are separate from and in addition to any annuity payments if you choose to annuitize your contract. Once started, Long Life Benefit Payments will continue as long as the Long Life Benefit Annuitant is alive. If after the 10th contract anniversary the Contract Value is withdrawn or the Contract Value is reduced to zero (unless reduced for required minimum distribution purposes), the GLLB Rider will remain in effect, Long Life Benefit Payments will not be reduced, and payments will begin on the Long Life Benefit Commencement Date.

Reduced Long Life Benefit Payments:  We will reduce your Long Life Benefit Payments if, prior to the 10th contract anniversary, the Contract Value is annuitized, the Contract Value is reduced to zero for any reason, or the Contract Value remains insufficient to cover the rider charge after the grace period allowed. If 60 days prior to a contract anniversary your Contract Value is insufficient to cover the rider charge, we will provide you written notice of the deficit and allow you a 60-day period to make additional Purchase Payments to the contract. (For this purpose, we will waive the $10,000 minimum Purchase Payment requirement in order to allow you to make such additional Purchase Payments.) If, after the 60-day period, the Contract Value remains insufficient to assess the rider charge, we will reduce your Long Life Benefit Payments. We will send you a new contract data page reflecting the amount of the reduced Long Life Benefit Payment. Once the Long Life Benefit Payments have been reduced, a withdrawal of the Contract Value or reduction of the Contract Value to zero for any reason will not impact your payments. The GLLB Rider will remain in effect and the reduced Long Life Benefit Payments will begin on the Long Life Benefit Commencement Date.

A reduction in Long Life Benefit Payments is permanent and the rider charge will no longer be assessed. If the reduced Long Life Benefit Payment amount is less than $500, we may change the payment frequency. The reduced Long Life Benefit Payments begin on the Long Life Benefit Commencement Date as originally stated in your contract and are calculated based upon the rider charges previously paid.

To calculate the reduced Long Life Benefit Payments we calculate an accumulated amount (as described below) based upon the rider charges paid and apply this amount to minimum annuity factors based on the Annuity 2000 mortality table as shown in your contract. The reduced Long Life Benefit Payments are not proportionate. They are reduced to the minimums allowed by state law and may be significantly less

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than the original Long Life Benefit Payments. In the following example, the reduced amount is calculated as eighty-seven and one-half percent (87.5%) of the rider charges paid, less fifty dollars ($50) per year, accumulated to the end of the deferral period at an interest rate of three percent (3%) per year. These amounts and percentages are based on your state’s nonforfeiture laws that set the values and percentages that may be used to calculate the smallest reduced benefits payable under the GLLB Rider.

Example:  Assume that a 65 year old male purchased a non-qualified contract and elected the GLLB with a 15-year deferral period and a Long Life Benefit Payment of $250 per month. This resulted in an annual rider charge of $1,000 for the first 10 contract years. In the 8th Contract Year, the Contract Value was reduced to zero causing a reduction in the Long Life Benefit Payments. The reduced amount would be calculated by multiplying the $7,000 paid in rider charges by 87.5%, less $50 per year, accumulated at 3% interest to the end of the deferral period. This is equal to $7,563.31. The $7,563.31 is applied to the annuity purchase rate table for an 80 year old (65 plus 15) male resulting in a reduced Long Life Benefit Payment of $60.41 per month. The reduced Long Life Benefit Payment will begin on the original Long Life Benefit Commencement Date.

The GLLB Rider issued with a qualified contract:  If the GLLB Rider is issued with a qualified contract the Owner must be the Annuitant under the contract, the Long Life Benefit Annuitant under the GLLB Rider, and the Payee.

Federal tax law requires generally that you begin taking required minimum distributions from your qualified contract commencing no later than the required beginning date. If the Annuity Date/Long Life Benefit Commencement Date is later than the required beginning date, any distribution taken in the form of withdrawals from your contract or GLLB Rider can adversely affect the benefits under the contract and the GLLB Rider. See the discussion of Qualified Contracts in “Section 6 - Taxes” You must complete a required minimum distributions election form each year you wish to take the required minimum distributions from your Focus contract or, when permitted, from the GLLB Rider. If your Contract Value is not sufficient to cover the required minimum distributions attributed to your Focus contract, you may take the shortfall from the GLLB Rider. Any required minimum distribution from the rider must be taken prior to the Long Life Benefit Commencement Date. If you choose to take some or all of your required minimum distribution from the GLLB Rider, we will adjust your Long Life Benefit Payment amount and send you a new contract data page reflecting the amount of the adjusted Long Life Benefit Payment. Your adjusted Long Life Benefit Payment will be reduced by a percentage which is equal to:

• The dollar amount which will be taken from the GLLB Rider to satisfy the required minimum distribution; divided by

• your life expectancy, as determined under federal Income Tax regulations, multiplied by the required minimum distribution amount attributed to your GLLB Rider.

Your Long Life Benefit Payment amount will not be reduced below the minimums allowed by state law as described above under Reduced Long Life Benefit Payments. You may only take required minimum distributions from the GLLB Rider if your Contract Value has been depleted.

Termination of Rider:  When the Long Life Benefit Annuitant dies, the rider will be terminated. The date of termination will be the date of death. Once the rider is terminated no further rider charges will apply. Any rider charges assessed after the Long Life Benefit Annuitant’s death will be returned once proof of death acceptable to us is received in our Home Office. It is important that we are notified of the death of the Long Life Benefit Annuitant as promptly as possible.

We will pay any Long Life Benefit Payments (including reduced Long Life Benefit Payments) even if you withdraw or annuitize your entire Contract Value prior to the Long Life Benefit Commencement Date as long as the Long Life Benefit Annuitant is living on the Long Life Benefit Commencement Date. After the Long Life Benefit Commencement Date, Long Life Benefit Payments will continue until the Long Life Benefit Annuitant dies. Upon the death of the Long Life Benefit Annuitant, the Long Life Benefit Payments will end and the GLLB Rider will terminate.

Proof of Age or Sex:  We may require proof of age (and sex for non-qualified contracts) before beginning Long Life Benefit Payments. If the age (or sex for non-qualified contracts) of the Long Life Benefit Annuitant has been misstated, Long Life Benefit Payments will be based on the corrected information. Underpayments will be made up in a lump sum with the next scheduled payment. Overpayments will be deducted from future payments until the total is repaid. We will not credit interest on underpayments or charge interest on overpayments. We may require evidence satisfactory to us that the Long Life Benefit Annuitant is living before we make any payment.

9. DEATH BENEFIT AND OPTIONAL DEATH BENEFIT RIDER

STANDARD DEATH BENEFIT AND AGE EXTENSION RIDER

Standard Death Benefit

Your contract provides you with a standard death benefit payable during the Accumulation Phase. If you are younger than age 75, the standard death benefit is designed to protect your Contract Value from potentially poor investment performance and the impact that poor investment performance could have on your death benefit. When you die and you are younger than age 75 at the time of death, the standard death benefit is the greater of:

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(a) Your Contract Value on the date all proof of death acceptable to us, such as a certified death certificate, plus written direction regarding how to pay the death benefit are completed and in a form acceptable to us. If we have not received all the required paperwork by the 6-month anniversary of death, then we will use the 6-month anniversary Contract Value as described in the Payment of Death Benefit section below;

AND

(b) 100% of Purchase Payments with a proportional deduction for withdrawals and associated charges, including charges for the GLLB Rider. All withdrawals and charges reduce this portion of the calculation in the same proportion that the Contract Value was reduced by the withdrawal and charges. In your contract, part (b) is referred to as the “guaranteed minimum death benefit”.

If (b) is greater than (a), then we will add money to your contract to meet the guaranteed minimum provided by this standard death benefit. This additional amount will be allocated to the Sub-accounts in the same proportion that Purchase Payments were last allocated. Thereafter, the Contract Value will be subject to investment performance and applicable charges until the date the death benefit is paid. We will add no more than $1 million to your contract to satisfy the standard death benefit.

The standard death benefit is your Contract Value, when:

• You are age 75 or older at the time of death;

• There are joint Owners and the younger joint Owner dies; or

• You assign your contract or elect to change the ownership of your contract.

In other words, item (b) above is set to zero, and your Contract Value is the death benefit.

Therefore, naming joint Owners and making ownership changes will have an impact on your contract. You should consult your agent or other advisor if you have questions.

Example One:  Assume Purchase Payments total $100,000 and no withdrawals have been made. The sole Owner is age 65 and the Beneficiary submits all required information to us for processing the death claim by the third-month anniversary of the Owner’s death. The Contract Value on the third-month anniversary is $90,000.

The death benefit equals the greater of

(a) $90,000; and

(b) $100,000.

Therefore, your standard death benefit is $100,000, and we will add $10,000 to the contract in the same investment allocation as the current Contract Value is invested.

If in this example the sole Owner had been age 78, there would be no guaranteed minimum death benefit. The Beneficiary would receive $90,000.

Example Two:  Assume the same facts as above but you took a withdrawal of $50,000 prior to your death leaving a Contract Value of $40,000. Your withdrawal reduces (b) in the same proportion that the Contract Value was reduced by the withdrawal as follows:

$100,000 x (40,000/90,000) = $44,444.44

The death benefit equals the greater of

(a) $40,000; and

(b) $44,444.44.

Therefore, your standard death benefit is $44,444.44 and we will add $4,444.44 to the contract in the same investment allocation as the current Contract Value is invested. In this example, the death benefit was reduced by more than the dollar amount of the withdrawal.

Example Three:  Assume the same facts as Example One above except the Contract Value on the third-month anniversary is $125,000.

The death benefit equals the greater of

(a) $125,000; and

(b) $100,000.

Because the Contract Value exceeds the guaranteed minimum death benefit of $100,000, no additional money will be added by us to the contract, and the Beneficiary will receive $125,000.

Guaranteed Minimum Death Benefit Age Extension Rider(“GMDB-Age Extension rider”)

You may purchase the GMDB - Age Extension rider if available in your state. This benefit is designed to protect your Contract Value from potentially poor investment performance for a longer period of time. It is calculated in the same manner as the standard death benefit described above, but it allows you to extend the guaranteed minimum death benefit of part (b) above to age 95. This is an optional rider available under the contract for an additional charge. If you are under age 75 on the Contract Date, you may elect this rider. If the contract is owned by joint Owners, both Owners must be under age 75 as of the Contract Date to elect this rider. You may elect this rider only at the time you purchase the contract.

PAYMENT OF DEATH BENEFIT

We will pay the death benefit upon receipt at our Home Office of proof of death acceptable to us, such as a certified copy of a death certificate, plus written direction from at least one eligible recipient of the death benefit proceeds regarding how to pay the death benefit payment and any other document, forms or information we need as described in your contract. The amount of the death benefit will include any interest required by state law.

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If we are required under the standard death benefit to add money to your contract, then we will calculate the amount to be added on the date we receive due proof of death acceptable to us and written direction from at least one eligible recipient of the death benefit regarding how to pay the death benefit. The money added will be allocated to the Sub-accounts according to the current allocation instructions on file for your Purchase Payments as of that date. We will add no more than $1 million to your contract to satisfy the standard death benefit.

If on the 6-month anniversary of the date of death we have not received all the information needed to process the death claim and we are required to add money to your contract under the standard death benefit, we will add the required amount and credit the difference with interest at the Fidelity VIP Money Market Portfolio rate from the 6-month anniversary until the date we receive the required information. At that time we will allocate this additional amount, with the credited interest, to the Sub-accounts in the same proportion that Purchase Payments were last allocated. Thereafter, the Contract Value will be subject to investment performance and applicable charges until the date the death benefit is paid.

Example:  Assume Purchase Payments total $100,000 and no withdrawals have been made. The sole Owner is age 65, and the Beneficiary submits all required information to us on the 8-month anniversary of the Owner’s death when the Contract Value is $85,000. The Contract Value on the six-month anniversary is $95,000.

The death benefit is the greater of

(a) $95,000; and

(b) $100,000.

Therefore, the death benefit is $100,000 and we will add $5,000, plus interest from the 6-month anniversary to the 8-month anniversary based on the Fidelity Money Market Portfolio, to the contract in the same investment allocation as the current Contract Value is invested.

If the Beneficiary or surviving Owner chooses to leave money invested in the contract rather than taking it in a lump sum, then, thereafter, the Contract Value will be subject to investment performance and applicable contract charges until the date the entire death benefit is paid out. This value will usually go up or down. Thus, we should be notified of a death as promptly as possible to limit the risk of a decline in benefit value.

Payment Options

Under a non-qualified contract, the death benefit may be paid as:

1) a lump sum payment or series of withdrawals that are completed within five years from the date of death; or

2) annuity payments made over the Beneficiary’s life or life expectancy. To receive annuity payments, the Beneficiary must make this election within 60 days from our receipt of proof of death. Annuity payments

must begin within one year from the date of death. Once annuity payments begin they cannot be changed.

Under a qualified contract, different death benefit elections may be available depending upon the retirement plan.

If your Beneficiary chooses a lump sum, then we value the death benefit as of the next close of the NYSE after we receive all required information and pay it within 7 days. If your Beneficiary chooses to make a series of withdrawals over time as provided in option 1 above, then your Beneficiary will pay all charges and expenses as described in the Charges and Expenses section of this prospectus, except surrender charges, so long as the death benefit remains invested in the contract. Your Beneficiary will also be subject to investment performance until the date the entire death benefit is paid out.

In some cases, a spouse who is entitled to receive a death benefit may have the option to continue the contract instead. If you entered into a civil union your rights to continue the contract may be limited under federal laws. See “Section 6 - Taxes” for more information. If this spouse is also the oldest joint Owner, the standard death benefit will apply on the death of this spouse. Otherwise, the death benefit on the death of your spouse will be the Contract Value.

If the age of the Annuitant or contract Owner has been misstated on the contract application, the amount of any death benefit payable shall be determined based upon the correct age of the Annuitant or contract Owner.

DEATH DURING THE ACCUMULATION PHASE

The death benefit during the Accumulation Phase is payable as follows:

• surviving Owner; or if none, then

• surviving primary Beneficiaries; or if none, then

• surviving contingent Beneficiaries; or if none, then

• estate of the last Owner to die.

If the Annuitant is not an Owner and the Annuitant dies before the Annuity Date, you must designate a new Annuitant. If no designation is made within 30 days after we are notified of the Annuitant's death, you will become the Annuitant. If this contract is owned by a non-natural person (e.g., a corporation or trust), the death of the Annuitant will be treated as the death of an Owner.

DEATH DURING THE INCOME PHASE

If an Owner dies during the Income Phase, then any amounts paid after the Owner’s death will depend on which annuity option was selected. If an Owner dies while annuity payments are being paid, we will pay the remaining annuity payments, if any, in accordance with that option. If the Annuitant is not an Owner and dies after the Annuity Date, then we will continue paying any remaining annuity payments to the Payee designated by the Owner. The death benefit or remaining annuity payments

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will be distributed at least as rapidly as under the annuity option then in effect. See Section 2 - Annuity Payments for more information.

The right to change the Payee for remaining annuity payments under another annuity option is determined as follows:

• surviving Owner; or if none, then

• surviving primary Beneficiary; or if none, then

• surviving contingent Beneficiary; or if none, then

• estate of the last Owner to die.

10. OTHER INFORMATION

SYMETRA LIFE

Symetra Life Insurance Company was incorporated as a stock life insurance company under Washington law on January 23, 1957 and was formerly named Safeco Life Insurance Company. On or about August 2, 2004, Symetra Financial Corporation, a financial services holding company, became the owner of Safeco Life Insurance Company. On September 1, 2004, Safeco Life Insurance Company changed its name to Symetra Life Insurance Company. Symetra Life Insurance Company is a wholly owned subsidiary of Symetra Financial Corporation. We provide individual and group life, accident and health insurance, and annuity products and are licensed to do business in the District of Columbia and all states except New York.

SEPARATE ACCOUNT

We established Symetra Separate Account C (formerly Safeco Separate Account C) (“Separate Account”) under Washington law on September 14, 1993. The Separate Account holds the assets that underlie Contract Values invested in the Sub-accounts. The Separate Account was registered with the SEC as a unit investment trust under the Investment Company Act of 1940, as amended on January 28, 1994.

Under Washington law, the assets in the Separate Account are the property of Symetra Life. However, assets in the Separate Account that are attributable to contracts are not chargeable with liabilities arising out of any other business we may conduct. Income, gains and losses (realized and unrealized), resulting from assets in the Separate Account are credited to or charged against the Separate Account without regard to other income, gains or losses of Symetra Life. Promises we make in the contract are general corporate obligations of Symetra Life and are not dependent on assets in the Separate Account.

CHANGES TO THE SEPARATE ACCOUNT

Where permitted by applicable law, we reserve the right to make certain changes to the structure and operation of the Separate Account. We will not make any such changes without receiving any necessary approval of the SEC and applicable state insurance departments. We will notify you of any changes in writing. These changes include, among others, the right to:

• Transfer assets supporting the contracts from one Sub-account to another or from the Separate Account to another separate account;

• Combine the Separate Account with other separate accounts, and/or create new separate accounts;

• Deregister the Separate Account, or operate the Separate Account as a management investment company, or as any other form permitted by law;

• Manage the Separate Account under the direction of a committee at any time;

• Make any changes required by applicable law or regulation; and

• Modify the provisions of the contract to reflect changes to the Sub-accounts and the Separate Account and to comply with applicable law.

Some, but not all, of these future changes may be the result of changes in applicable laws or interpretations of law. We reserve the right to make other structural and operational changes affecting the Separate Account.

DISTRIBUTION (PRINCIPAL UNDERWRITER)

The contracts are distributed by Symetra Securities, Inc. (“SSI”). They are sold by individuals who, in addition to being licensed to sell variable annuity contracts for Symetra Life, are also registered representatives of broker-dealers who have a current sales agreement with SSI and Symetra Life. SSI is an affiliate of Symetra Life and is located at 777 108th Avenue NE, Suite 1200, Bellevue, Washington 98004. It is registered as a broker-dealer with the SEC under the Securities Act of 1934 and is a member of the Financial Industry Regulatory Authority (“FINRA”). No amounts are retained by SSI for acting as principal underwriter for Symetra Life variable products.

Registered representatives who solicit sales of the contracts receive a portion of the commission payable to the broker-dealer firm, depending on the agreement between the broker-dealer and the registered representative. A broker-dealer firm or registered representative may receive different commissions for selling one annuity over another annuity and may favor one annuity provider over another due to different compensation rates. If you would like information about what your registered representative and his or her broker-dealer receives in connection with the purchase of your contract, please ask your registered representative.

Furthermore, we and SSI offer the contracts through our affiliated broker-dealer, Symetra Investment Services, Inc. (“SIS”). Because of this affiliation, SIS and its registered representatives may favor Symetra Life’s products. We do not pay SIS different commissions from what we pay unaffiliated broker-dealers, but SIS may pay its registered representatives higher commission or bonuses for selling Symetra Life products rather than another company’s annuity product.

We may also contract with SIS and unaffiliated firms to act as wholesalers for us and assist us in offering and selling our contracts to broker-dealers and their registered representatives. Wholesalers may also be called “independent marketing organizations” and provide training, marketing and other sales-

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related functions. Wholesalers may also provide administrative services to us in connection with the contracts. Some wholesalers may also directly sell the contracts. Wholesalers may be paid commissions and overrides.

We generally pay commissions as a percentage of Purchase Payments invested in the contract. At the option of the broker-dealer, we may pay lower compensation on Purchase Payments but pay a periodic asset-based commission beginning after the first Contract Year. The amount and timing of the commission may differ depending on the agreement between us and the broker-dealer but is not expected to be more than 6.0% of Purchase Payments. We may also pay additional commission if you choose to receive your Contract Value in the form of a fixed annuity option. We do not expect this commission to exceed 2.25% of the Contract Value applied to purchase a fixed annuitization option. In addition, allowances, and bonuses may be paid to broker-dealers and/or other distributors of the contracts, and we may also provide non-cash compensation in connection with the promotion of the contracts, including conferences and seminars, and items of small value, such as promotional gifts, meals or tickets to sporting or entertainment events. A bonus dependent upon persistency is one type of bonus that may be paid.

To the extent permitted by FINRA rules, promotional incentives or payments may also be provided to broker-dealers and wholesalers based on sales volumes, the assumption of wholesaling functions or other sales-related criteria. Other payments may be made for other services that do not directly involve the sale of the contracts. These services may include the recruitment and training of personnel, production of promotional literature, and similar services. We may also make additional payments to broker-dealer firms in order to be included on their approved product lists or to be part of “preferred product” arrangements. You may contact us for the list of firms, if any, with which we may have such arrangements.

These additional incentives or payments are calculated in different ways and are not offered to all broker-dealer firms. They may be based on assets under management, purchase payments received, or other criteria. These additional incentives or payment could create an incentive for your registered representative, and the broker-dealer with which they are associated to recommend products that pay them more than others.

This contract does not assess a front-end sales charge. You indirectly pay for commissions and other sales expenses primarily, but not exclusively, through: the surrender charge and the mortality and expense risk charge. We may also pay for sales and distribution expenses out of any payments we or SSI receive from the underlying Portfolios for providing administrative, distribution and other services to the Portfolios.

From time to time, we may pay organizations, associations and non-profit organizations fees to endorse or sponsor our variable annuity contracts. These organizations are compensated for

their endorsement or sponsorship of our variable annuity contracts in various ways. Primarily, they receive a flat fee from us. We may also compensate these organizations by our funding of their programs, scholarships, events or awards.

AMENDMENTS TO THE CONTRACT

We reserve the right to amend the contract to meet the requirements of applicable federal or state laws or regulations. You will be notified in writing of any changes, modifications or waivers.

LEGAL PROCEEDINGS

There are no legal proceedings to which the Separate Account or SSI is a party. In the ordinary course of business, Symetra Life is engaged in various kinds of litigation, including class action and other lawsuits, or in arbitration. In some class action and other lawsuits involving insurance companies and other financial service providers, substantial damages have been sought and material settlement payments have been made. Although the outcome of any litigation cannot be predicted with certainty, at the present time it appears that there are no pending or threatened lawsuits that are likely to have a material adverse effect on the Separate Account, on Symetra Life's ability to meet its obligations under the contract, or on SSI's ability to perform under its principal underwriting agreement.

RIGHT TO SUSPEND ANNUITY PAYMENTS, TRANSFERS, OR WITHDRAWALS

We may be required to suspend or postpone payment of annuity payments, transfers, or withdrawals from the Sub-accounts for any period of time when:

• the NYSE is closed (other than customary weekend or holiday closings);

• trading on the NYSE is restricted;

• an SEC declared emergency exists such that disposal of or determination of the value of the Sub-accounts is not reasonably practicable; or

• the SEC, by order, so permits for your protection.

Federal laws designed to counter terrorism and prevent money laundering by criminals might, in certain circumstances, require us to reject a Purchase Payment and/or “freeze” your contract. If these laws apply in a particular situation, we would not be allowed to process any request for withdrawals, surrenders, or death benefits, make transfers, or continue making payments under an annuity payment option. We may also be required to provide additional information about you or your contract to government regulators.

REDUCTION OF CHARGES OR ADDITIONAL AMOUNTS CREDITED

Under some circumstances we may expect to experience lower costs or higher revenues associated with issuing and administering certain contracts. For example, sales expenses are expected to be less when contracts are sold to a large group of individuals. In these situations, we may have lower

Symetra Focus Prospectus

37

administrative costs due to the ability to centralize communications with one large group rather than individualized communications. Thus administrative tasks, such as the processing forms and handling of Purchase Payments, withdrawals and surrenders may be administered more efficiently. Under such circumstances we may pass a portion of these anticipated savings on to you by reducing Owner transaction charges (including the surrender charge).

We may also take such action in connection with contracts sold to our officers, directors, and employees and their family members, employees of our affiliates and their family members, and registered representatives and employees of broker-dealers that have a current selling agreement with us. In each circumstance such actions will be reasonably related to the savings or revenues anticipated and will be applied in a non-discriminatory manner. These actions may be withdrawn or modified by us at any time.

WEBSITE INFORMATION

You can find more information about the Symetra Focus Variable Annuity contract as well as other products and financial services offered by Symetra Life Insurance Company on the Internet at http://www.symetra.com. This website is frequently updated with new information and can help you locate a representative near you.

FINANCIAL STATEMENTS

The statutory-basis financial statements of Symetra Life Insurance Company and the financial statements of Symetra Separate Account C are included in the Statement of Additional Information.

TABLE OF CONTENTS OF THE STATEMENT OF ADDITIONAL INFORMATION

General Information

Services

Purchase of Contracts

Reduction or Waivers of Charges

Underwriter

Additional Tax Information

Annuity Provisions

Financial Statements

Symetra Focus Prospectus

38

(cut along dotted line)

If you would like a free copy of the Statement of Additional Information dated May 1, 2010, for this prospectus, please complete this form, detach and mail to:

Symetra Life Insurance Company

PO Box 3882

Seattle, WA 98124-3882

Please send me a free copy of the Statement of Additional Information for the Symetra Focus Variable Annuity at the following address:

Name:    

Mailing Address:    

Symetra Focus Prospectus

39

APPENDIX A:

CALCULATION OF SURRENDER AND WITHDRAWAL CHARGES

EXAMPLE 1 - Surrender Charge Only

Assume you purchase a contract on January 4th with an initial Purchase Payment of $100,000 and allocate the full amount to Sub-account A. Sub-account A has a unit value at the close of business on January 4th of 10.000 so you have 10,000 units of Sub-account A. On July 1^st of the same year, you request to withdraw $25,000.

AS OF JULY 1st
Number of Units Owned	=	10,000
Unit Value of Sub-account A	=	$20.00
Contract Value (# of Units multiplied by Unit Value)	=	$200,000
10% free withdrawal amount	=	$20,000

For your requested withdrawal amount of $25,000, you will receive $20,000 (10% of Contract Value) without a surrender charge. The remaining $5,000 will be assessed a surrender charge of 7% because the Purchase Payment has been invested in the contract for less than one year.

$5,000 times 7%	=	$350.00
$5,000 - $350.00	=	$4,650.00

After the surrender charge is deducted you will receive a payment of $24,650.00 but a total of $25,000.00 will be removed from your Contract Value. After the withdrawal, your units will have been reduced by 1,250 units and you will own 8,750 units in Sub-account A.

Amount of Withdrawal divided by Unit Value
($25,000.00 divided by $20.00)	=	1,250 Units
# of Units Owned Prior to Withdrawal minus the # of Units Reduced by the Withdrawal
(10,000 minus 1,250)	=	8,750 Units

EXAMPLE 2: Surrender Charge and Withdrawal Charge

Assume that on December 1st of the same year, you request a withdrawal of $20,000. You own 8,750 units of Sub-account A and the value of the Sub-account as of December 1st is $15.00.

Contract Value (# of Units multiplied by Unit Value)	=	$	131,250
10% free withdrawal amount of current Contract Value plus the previous withdrawals ($131,250 + $25,000 = $156,250)	=		$15,625
Previously Requested Withdrawal Amount	=		$25,000

Because the surrender charge was waived on the first 10% of Contract Value withdrawn during the contact year (the July 1^st withdrawal of $25,000), the waived charge is not available for this withdrawal. The applicable surrender charge is equal to:

7% of $20,000 = $ 1,400.00

Since this is the second withdrawal during the contract year, a $25.00 withdrawal charge also applies. You receive a payment of $18,575 but $20,000 will be withdrawn from the contract to include the surrender charge ($1,400.00) and withdrawal charge ($25.00). After the withdrawal, your units in Sub-account A are reduced by 1,333.333 units and you will own 7,416.677 units in Sub-account A.

Amount of Withdrawal divided by Unit Value
($20,000 divided by 15.000)	=	1,333.333 Units
# of Units Owned Prior to Withdrawal minus the # of Units Reduced by the Withdrawal
(8,750 minus 1,333.333)	=	7,416.667 Units
Remaining Contract Value (Units multiplied by Unit Value)	=	$111,250

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A-1

APPENDIX B: ACCUMULATION UNIT VALUE HISTORY

Accumulation Unit Value History

Except for Sub-accounts which were not offered under the contract as of December 31, 2009, the following table includes Accumulation Unit values and the total number of Annuity Units outstanding for the periods indicated. This data has been extracted from the Separate Account’s Financial Statements. This information should be read in conjunction with the Separate Account’s Financial Statements and related notes which are included in the SAI.

We make deductions for certain charges as part of our calculation of the Accumulation Unit Value and Annuity Units. The Tiers shown in the tables correlate to the charge taken for the asset-related administration charge. Tier I represents the 0.40% charge, Tier II represents the 0.35% charge, Tier III represents the 0.25% charge, Tier IV represents the 0.15% charge and Tier V represents the 0.05% charge.

The table below shows the Accumulation Unit Values and Annuity Units assuming you select no optional benefits.

	Tier I	Tier II	Tier III	Tier IV	Tier V
DWS SMALL CAP INDEX VIP - CLASS A SHARES
May 16, 2007 value (initial public offering) $10.000
2009 Value	$8.711	$8.718
2009 Units	713	5,148
2008 Value	$6.976	$6.978
2008 Units	-	1,958
FIDELITY VIP INDEX 500 PORTFOLIO - INITIAL CLASS SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
2009 Value	$7.429	$7.439
2009 Units	14,631	10,756
2008 Value	$5.948	$5.952
2008 Units	11,830	7,137
2007 Value	$9.569	$9.571
2007 Units	2,650	1,858
FIDELITY VIP MONEY MARKET PORTFOLIO - INITIAL CLASS SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
2009 Value	$10.318	$10.331	$10.358
2009 Units	142,108	38,846	25,590
2008 Value	$10.383	$10.391	$10.408
2008 Units	48,309	43,178	14,477
2007 Value	$10.215	$10.218	$10.224
2007 Units	28,263	28,255	-
IBBOTSON AGGRESSIVE GROWTH ETF ASSET ALLOCATION PORTFOLIO - CLASS I SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
2009 Value	$7.631	$7.641	$7.661
2009 Units	37,714	1,156	7,262
2008 Value	$6.053	$6.058	$6.067
2008 Units	14,539	11,758	-
2007 Value	$9.673	$9.676	$9.682
2007 Units	6,045	-	-
IBBOTSON BALANCED ETF ASSET ALLOCATION PORTFOLIO - CLASS I SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
2009 Value	$8.810	$8.822	$8.844
2009 Units	35,160	68,011	10,038
2008 Value	$7.458	$7.464	$7.475
2008 Units	41,613	21,247	40,611
2007 Value	$9.913	$9.916	$9.921
2007 Units	2,503	14,394	29,163

Symetra Focus Prospectus

B-1

Accumulation Unit Value History (Continued)

	Tier I	Tier II	Tier III	Tier IV	Tier V
IBBOTSON CONSERVATIVE ETF ASSET ALLOCATION PORTFOLIO - CLASS I SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
2009 Value	$10.315	$10.328
2009 Units	4,524	6,992
2008 Value	$9.630	$9.637
2008 Units	4,152	6,964
2007 Value	$10.368	$10.371
2007 Units	-	-
IBBOTSON GROWTH ETF ASSET ALLOCATION PORTFOLIO - CLASS I SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
2009 Value	$8.129	$8.139	$8.160
2009 Units	29,723	2,140	6,823
2008 Value	$6.594	$6.600	$6.610
2008 Units	31,250	-	48,731
2007 Value	$9.730	$9.733	$9.738
2007 Units	7,594	-	-
IBBOTSON INCOME & GROWTH ETF ASSET ALLOCATION PORTFOLIO - CLASS I SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
2009 Value	$9.517	$9.529
2009 Units	2,671	19,709
2008 Value	$8.482	$8.489
2008 Units	2,676	19,163
2007 Value	$10.109	$10.112
2007 Units	-	20,420
VANGUARD VIF - BALANCED PORTFOLIO SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
2009 Value	$9.276	$9.288	$9.312
2009 Units	26,972	3,006	8,215
2008 Value	$7.650	$7.656	$7.668
2008 Units	23,163	774	8,215
2007 Value	$10.014	-	$10.023
2007 Units	16,968	-	8,215
VANGUARD VIF - HIGH YIELD BOND PORTFOLIO SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
2009 Value	$10.255	$10.268	$10.294
2009 Units	23,216	21,049	14,260
2008 Value	$7.486	$7.492	$7.503
2008 Units	19,577	24,989	4,078
2007 Value	$9.721	$9.724	$9.730
2007 Units	4,863	2,847	-
VANGUARD VIF - INTERNATIONAL PORTFOLIO SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
2009 Value	$7.894	$7.904	$7.925
2009 Units	45,640	52,809	27,006
2008 Value	$5.604	$5.608	$5.617
2008 Units	39,019	30,468	10,424
2007 Value	$10.312	$10.315	$10.321
2007 Units	7,003	4,174	-

Symetra Focus Prospectus

B-2

Accumulation Unit Value History (Continued)

	Tier I	Tier II	Tier III	Tier IV	Tier V
VANGUARD VIF - MID-CAP INDEX PORTFOLIO SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
2009 Value	$7.339	$7.349	$7.368
2009 Units	77,366	80,542	46,850
2008 Value	$5.299	$5.304	$5.312
2008 Units	63,131	68,527	25,233
2007 Value	$9.232	$9.235	$9.240
2007 Units	12,299	6,845	8,639
VANGUARD VIF - REIT INDEX PORTFOLIO SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
2009 Value	$6.299	$6.307	$6.323
2009 Units	23,412	28,953	11,509
2008 Value	$4.944	$4.947	$4.955
2008 Units	19,669	23,542	6,085
2007 Value	$7.985	$7.988	$7.992
2007 Units	1,909	1,834	-
VANGUARD VIF - TOTAL BOND MARKET INDEX PORTFOLIO SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
2009 Value	$11.389	$11.404	$11.433
2009 Units	64,371	94,180	48,193
2008 Value	$10.896	$10.905	$10.922
2008 Units	49,981	102,355	36,900
2007 Value	$10.496	$10.499	$10.505
2007 Units	9,735	10,830	8,168
VANGUARD VIF - TOTAL STOCK MARKET INDEX PORTFOLIO SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
2009 Value	$7.427	$7.437	$7.456
2009 Units	99,987	141,114	61,256
2008 Value	$5.870	$5.874	$5.884
2008 Units	82,661	111,431	34,461
2007 Value	$9.486	$9.489	$9.494
2007 Units	13,969	13,314	8,399

The table below shows the Accumulation Unit values for those Sub-accounts which had assets invested in the GMDB - Age Extension rider as of December 31, 2009.

	Tier I	Tier II	Tier III	Tier IV	Tier V
DWS SMALL CAP INDEX VIP - CLASS A SHARES
May 16, 2007 value (initial public offering) $10.000
GMDB 2009 Value	-	$8.704
GMDB 2009 Units	-	870
GMDB 2008 Value	-	$6.973
GMDB 2008 Units	-	-
FIDELITY VIP INDEX 500 PORTFOLIO - INITIAL CLASS SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
GMDB 2009 Value	$7.410	$7.419
GMDB 2009 Units	-	19,698
GMDB 2008 Value	$5.938	$5.943
GMDB 2008 Units	19,718	-
GMDB 2007 Value	$9.563	$9.566
GMDB 2007 Units	-	-

Symetra Focus Prospectus

B-3

Accumulation Unit Value History (Continued)

	Tier I	Tier II	Tier III	Tier IV	Tier V
FIDELITY VIP MONEY MARKET PORTFOLIO - INITIAL CLASS SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
GMDB 2009 Value	$10.291	$10.304
GMDB 2009 Units	10,047	7,510
GMDB 2008 Value	$10.367	$10.375
GMDB 2008 Units	5,570	9,955
GMDB 2007 Value	$10.209	$10.212
GMDB 2007 Units	7,898	21,754
IBBOTSON BALANCED ETF ASSET ALLOCATION PORTFOLIO - CLASS I SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
GMDB 2009 Value	-	$8.799
GMDB 2009 Units	-	22,817
GMDB 2008 Value	-	$7.452
GMDB 2008 Units	-	22,817
GMDB 2007 Value	-	$9.910
GMDB 2007 Units	-	-
IBBOTSON CONSERVATIVE ETF ASSET ALLOCATION PORTFOLIO - CLASS I SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
GMDB 2009 Value	$10.289
GMDB 2009 Units	4,275
GMDB 2008 Value	$9.615
GMDB 2008 Units	4,821
GMDB 2007 Value	$10.362
GMDB 2007 Units	-
IBBOTSON GROWTH ETF ASSET ALLOCATION PORTFOLIO - CLASS I SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
GMDB 2009 Value	$8.108	$8.118
GMDB 2009 Units	-	22,642
GMDB 2008 Value	$6.584	$6.589
GMDB 2008 Units	17,869	-
GMDB 2007 Value	$9.724	$9.727
GMDB 2007 Units	-	-
IBBOTSON INCOME & GROWTH ETF ASSET ALLOCATION PORTFOLIO - CLASS I SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
GMDB 2009 Value	$9.492
GMDB 2009 Units	771
GMDB 2008 Value	$8.469
GMDB 2008 Units	782
GMDB 2007 Value	$10.103
GMDB 2007 Units	-
VANGUARD VIF - BALANCED PORTFOLIO SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
GMDB 2009 Value	$9.252	$9.264	-	-	$9.336
GMDB 2009 Units	327	38,110	-	-	8,360
GMDB 2008 Value	$7.638	$7.644	-	-	$7.680
GMDB 2008 Units	332	39,579	-	-	-
GMDB 2007 Value	$10.009	$10.011	-	-	$10.029
GMDB 2007 Units	-	-	-	-	-

Symetra Focus Prospectus

B-4

Accumulation Unit Value History (Continued)

	Tier I	Tier II	Tier III	Tier IV	Tier V
VANGUARD VIF - HIGH YIELD BOND PORTFOLIO SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
GMDB 2009 Value	$10.228	$10.241	-	-	$10.321
GMDB 2009 Units	5,032	2,865	-	-	15,018
GMDB 2008 Value	$7.474	$7.480	-	-	$7.515
GMDB 2008 Units	2,274	4,538	-	-	17,452
GMDB 2007 Value	$9.716	$9.719	-	-	$9.735
GMDB 2007 Units	-	1,532	-	-	17,452
VANGUARD VIF - INTERNATIONAL PORTFOLIO SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
GMDB 2009 Value	$7.874	$7.884	-	-	$7.945
GMDB 2009 Units	6,626	6,365	-	-	20,206
GMDB 2008 Value	$5.595	$5.599	-	-	$5.626
GMDB 2008 Units	4,745	3,215	-	-	10,327
GMDB 2007 Value	-	$10.309	-	-	$10.327
GMDB 2007 Units	-	931	-	-	10,926
VANGUARD VIF - MID-CAP INDEX PORTFOLIO SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
GMDB 2009 Value	$7.320	$7.330	-	-	$7.387
GMDB 2009 Units	17,624	6,107	-	-	-
GMDB 2008 Value	$5.291	$5.295			$5.320
GMDB 2008 Units	10,567	10,048	-	-	43,299
GMDB 2007 Value	-	$9.229	-	-	$9.245
GMDB 2007 Units	-	3,660	-	-	43,299
VANGUARD VIF - REIT INDEX PORTFOLIO SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
GMDB 2009 Value	$6.282	$6.290	-	-	$6.339
GMDB 2009 Units	2,444	3,979	-	-	-
GMDB 2008 Value	$4.936	$4.940	-	-	$4.963
GMDB 2008 Units	1,640	1,806	-	-	11,181
GMDB 2007 Value	-	$7.983	-	-	$7.997
GMDB 2007 Units	-	955	-	-	11,181
VANGUARD VIF - TOTAL BOND MARKET INDEX PORTFOLIO SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
GMDB 2009 Value	$11.360	$11.374	-	-	$11.463
GMDB 2009 Units	18,865	25,879	-	-	96,229
GMDB 2008 Value	$10.879	$10.888	-	-	$10.939
GMDB 2008 Units	9,310	11,745	-	-	60,397
GMDB 2007 Value	$10.490	$10.493	-	-	$10.511
GMDB 2007 Units	-	5,244	-	-	60,397
VANGUARD VIF - TOTAL STOCK MARKET INDEX PORTFOLIO SUB-ACCOUNT
May 16, 2007 value (initial public offering) $10.000
GMDB 2009 Value	$7.408	$7.418	-	-	$7.475
GMDB 2009 Units	24,688	20,976	-	-	-
GMDB 2008 Value	$5.860	$5.865	-	-	$5.893
GMDB 2008 Units	12,235	11,676	-	-	52,408
GMDB 2007 Value	$9.481	$9.484	-	-	$9.500
GMDB 2007 Units	-	4,414	-	-	52,408

Symetra Focus Prospectus

B-5

SYMETRA FOCUS VARIABLE ANNUITY

STATEMENT OF ADDITIONAL INFORMATION

INDIVIDUAL FLEXIBLE PREMIUM DEFERRED VARIABLE ANNUITY CONTRACT

issued by

SYMETRA SEPARATE ACCOUNT C

and

SYMETRA LIFE INSURANCE COMPANY

This Statement of Additional Information (“SAI”) is not a prospectus and should be read in conjunction with the prospectus for the Individual Flexible Premium Deferred Variable Annuity Contract.

The prospectus concisely sets forth information that a prospective investor should know before investing. For a copy of the prospectus, call 1-800-796-3872 or write to Symetra Life Insurance Company, Retirement Services Department, P.O. Box 3882, Seattle, Washington 98124-3882.

This SAI and the prospectus are both dated May 1, 2010.

TABLE OF CONTENTS

	Page
GENERAL INFORMATION	2
SERVICES	2
Experts	2
Independent Registered Public Accounting Firm	2
PURCHASE OF CONTRACTS	2
REDUCTION OR WAIVERS OF CHARGES	2
UNDERWRITER	3
ADDITIONAL TAX INFORMATION	3
Note	3
General	3
Non-Qualified Annuity Contracts	4
Tax Treatment of Withdrawals – Non-Qualified Annuity Contracts	4
Qualified Contracts	4
Tax Treatment of Withdrawals - Qualified Contracts	6
Tax Sheltered Annuities - Withdrawal Limitations	7
Income Tax Withholding	8
Diversification	8
ANNUITY PROVISIONS	9
Annuity Unit Value	9
Variable Annuity Payments	9
Fixed Annuity Payments	10
FINANCIAL STATEMENTS	11

GENERAL INFORMATION

Terms and phrases used in this SAI have the meaning given to them in the prospectus.

Symetra Life Insurance Company (“Symetra Life”, “we”, and “us”), is a wholly-owned subsidiary of Symetra Financial Corporation, a holding company, the subsidiaries of which are engaged primarily in insurance and financial services businesses. Symetra Life Insurance Company was incorporated as a stock life insurance company under Washington state law on January 23, 1957 and formerly named Safeco Life Insurance Company. On September 1, 2004, Safeco Life Insurance Company changed its name to Symetra Life Insurance Company.

We established Symetra Separate Account C (“the Separate Account”) to hold assets that underlie contract values invested in a number of different variable annuity contracts. The Separate Account meets the definition of “separate account” under Washington state law and under the federal securities laws. The Separate Account is registered with the Securities and Exchange Commission (“SEC”) as a unit investment trust under the Investment Company Act of 1940, as amended. We maintain records of all Separate Account purchases and redemptions of the shares of the Sub-accounts.

Accumulation Units and variable annuity payments will reflect the investment performance of the Separate Account with respect to amounts allocated to it. Since the Separate Account is always fully invested in the shares of the Sub-accounts, its investment performance reflects the investment performance of those entities. The values of such shares held by the Separate Account fluctuate and are subject to the risks of changing economic conditions. The contract Owner bears the entire investment risk. There can be no assurance that the aggregate value in the contract and amount of variable annuity payments will equal or exceed the Purchase Payments made under a contract.

SERVICES

Experts

The statutory-basis financial statements and schedules of Symetra Life Insurance Company as of December 31, 2009 and 2008, and for each of the three years in the period ended December 31, 2009, and the financial statements of Symetra Separate Account C as of December 31, 2009, and for each of the two years in the period ended December 31, 2009, appearing in the Statement of Additional Information of the Registration Statement have been audited by Ernst & Young LLP, independent registered public accounting firm, as set forth in their reports thereon appearing elsewhere herein, and are included in reliance upon such reports given on the authority of such firm as experts in accounting and auditing.

Independent Registered Public Accounting Firm

The principal business address of Ernst & Young LLP is 999 Third Avenue, Suite 3500, Seattle, WA 98104-4086.

PURCHASE OF CONTRACTS

The contracts will be sold by licensed insurance agents in states where the contracts may be lawfully sold. The agents will be registered representatives of broker-dealers that are registered under the Securities Exchange Act of 1934 and members of Financial Industry Regulatory Authority (“FINRA”).

REDUCTION OR WAIVERS OF CHARGES

Under some circumstances we may expect to experience lower costs or higher revenues associated with issuing and administering certain contracts. For example, sales expenses are expected to be less when contracts are sold to a large group of individuals because we may have lower administrative costs due to the ability to centralize communications with one large group rather than individualized communications. Thus administrative tasks, such as the processing of forms and handling of Purchase Payments, withdrawals and surrenders may be administered more efficiently. In these situations, the amount of the surrender charge on the contracts may be reduced or eliminated.

2

Any reduction of the surrender charge will be determined by us after examination of all the relevant factors such as:

• The size and type of group to which sales are to be made;

• The total amount of Purchase Payments to be received;

• Any prior or existing relationship with us; and

• Other circumstances which would reduce our sales and other expenses.

If, after consideration of the foregoing factors, we determine that there will be a reduction in sales expenses, Symetra Life may provide for a reduction or elimination of the surrender charge.

The surrender charge may be eliminated when the contracts are issued to an officer, director or employee of Symetra Life or any of its affiliates. In no event will reductions or elimination of the surrender charge be permitted where reductions or elimination will be unfairly discriminatory to any person.

UNDERWRITER

Symetra Securities, Inc. (“SSI”), an affiliate of Symetra Life, acts as the principal underwriter for the contracts pursuant to an underwriter’s agreement with us. SSI is located at 777 108^th Avenue NE, Suite 1200, Bellevue, WA 98004. The contracts issued by the Separate Account are offered on a continuous basis. For the years ended December 31, 2009, 2008, and 2007 SSI received $3,719,093, $4,759,624, and $5,126,947 in commissions for the distribution of all annuity contracts funded through the Separate Account. SSI does not retain any portion of the commissions.

ADDITIONAL TAX INFORMATION

Note

The following description is based upon Symetra Life’s understanding of current federal income tax law applicable to annuities in general. Tax laws are complex and subject to change. We cannot predict the probability that any changes in the interpretation of the laws, or the laws themselves, will occur. Purchasers are cautioned to seek competent tax advice regarding the possibility of such changes. We do not guarantee the tax status of the contracts. Purchasers bear the complete risk that the contracts may not be treated as “annuity contracts” under federal income tax laws. It should be further understood that the following discussion is not exhaustive and that special rules not described in this SAI or the prospectus may be applicable in certain situations. Moreover, no attempt has been made to consider any applicable state or other tax laws.

General

Section 72 of the Internal Revenue Code of 1986, as amended, (“the Code”) governs taxation of annuities in general. An owner is generally not taxed on increases in the value of a contract until distribution occurs, either in the form of a lump sum payment, a withdrawal, or as annuity payments under the option elected. For a lump sum payment received as a total surrender (total redemption), the recipient is generally taxed on the portion of the payment that exceeds the cost basis in the contract. For a partial withdrawal payment, the recipient is taxed as if earnings are withdrawn first before the cost basis of the contract is withdrawn. The cost basis is generally the amount of non-deductible purchase payments which for qualified contracts may be zero. The taxable portion of the lump sum payment is taxed at ordinary income tax rates. Tax penalties may also apply.

For annuity payments, a portion of each payment in excess of an exclusion amount is includable in taxable income. The exclusion amount for payments based on a fixed annuity is determined by multiplying the payment by the ratio that the cost basis of the contract (adjusted for any period certain or refund feature) bears to the expected return under the contract. The exclusion amount for payments based on a variable annuity is determined by dividing the cost basis of the contract (adjusted for any period certain or refund guarantee) by the number of years over which the annuity is expected to be paid. Payments received after the investment in the contract has been recovered (i.e. when the total of the excludable amounts equals the investment in the contract) are generally fully taxable. For certain types of retirement plans there may be no cost basis in the contract within the meaning of Section 72 of the Code resulting in the annuity payments being fully includable in taxable income. Owners, payees and beneficiaries under the contracts should seek competent financial advice about the tax consequences of any distributions.

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Any death benefits paid under the contract are generally taxable to the beneficiary. The rules governing the taxation of distributions from an annuity contract, as discussed above, generally apply to the payment of death benefits and depend on whether the death benefits are paid as a lump sum or as annuity payments. Estate or gift taxes may also apply.

Symetra Life is taxed as a life insurance company under the Code. For federal income tax purposes, the Separate Account is not a separate entity from Symetra Life and its operations form a part of Symetra Life.

Non-Qualified Annuity Contracts

Individuals may purchase non-qualified annuity contracts without any purchase payment limits imposed under the Code. The Purchase Payments receive no tax benefit, deduction or deferral, but taxes on the increases in the value of the contract are generally deferred until withdrawn. If the Contract Value exceeds the aggregate Purchase Payments made, any amount withdrawn will be treated as coming first from the earnings and then, only after the income portion is exhausted, as coming from the principal. Withdrawn earnings are includable in gross income.

Under Section 72(u) of the Code, the earnings on Purchase Payments for the contracts will be taxed currently to the owner if the owner is not a natural person, e.g., a corporation or certain other entities. Such contracts will generally not be treated as annuities for federal income tax purposes. This treatment is not applied to contracts held by certain trusts or other entities as an agent for a natural person or to hold qualified retirement plan assets. Purchasers who are not natural persons should consult their own tax counsel or other tax adviser before purchasing a contract.

Under the Code, if two or more non-qualified annuity contracts are purchased from the same company within the same calendar year, they are treated as one annuity contract for purposes of determining the tax consequences of any distribution. As a result, withdrawals from any of such contracts will be taxed based upon the income in all of the contracts aggregated in the same calendar year. Such treatment may result in adverse tax consequences including more rapid taxation of the distributed amounts from such multiple contracts. For purposes of the aggregation rule, contracts received in a Section 1035 exchange will be considered issued in the year of the exchange. You should consult a tax adviser prior to purchasing more than one annuity in any calendar year.

Tax Treatment of Withdrawals – Non-Qualified Annuity Contracts

In addition to ordinary income tax, withdrawals from the contract may be subject to a ten percent (10%) penalty applied to the income portion of any premature withdrawals. The penalty is not imposed on amounts received: (a) after the taxpayer reaches age 59 ¹/2; (b) after the death of the owner; (c) if the taxpayer is totally disabled (for this purpose disability is as defined in Section 72(m)(7) of the Code); (d) in a series of substantially equal periodic payments made not less frequently than annually for the life (or life expectancy) of the taxpayer or for the joint lives (or joint life expectancies) of the taxpayer and his or her beneficiary; or (e) which are allocable to Purchase Payments made prior to August 14, 1982. With respect to (d) above, if the series of substantially equal periodic payments is modified before the later of your attaining age 59 ¹/2 or five years from the date of the first periodic payment, then the tax for the year of the modification is increased by an amount equal to the tax which would have been imposed (the 10% penalty tax) but for the exception, plus interest for the tax years in which the exception was used.

The above information does not apply to qualified contracts. However, separate tax withdrawal penalties and restrictions may apply to such qualified contracts. (See “Tax Treatment of Withdrawals - Qualified Contracts” below.)

Qualified Contracts

1. The following describes contracts offered to individual contract owners in order to allow individuals to accumulate savings for retirement. If your contract is issued as an Individual Retirement Annuity (“IRA”) or Roth Individual Retirement Annuity (“Roth IRA”), then we will issue the contract with language intended to qualify the contract as an IRA or Roth IRA. We will also provide the necessary administrative procedures to administer the IRAs and Roth IRAs in accordance with IRS requirements governing the sponsors of IRAs and Roth IRAs subject to the accuracy and completeness of the information you provide us. For SEP IRAs and SIMPLE IRAs, certain IRS requirements and administrative procedures will be provided by your employer, and your contract may be subject to the terms of the SEP IRA or SIMPLE IRA plan. Contracts issued in connection with SEP IRAs and SIMPLE IRAs may include special provisions that may restrict or modify the contract provisions and administrative services in the prospectus. There are generally maximum amounts that can be

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contributed each year to IRAs. IRA owners age 50 or older may be able to make additional “catch-up” Purchase Payments each year. If contributions are being made under a SEP or SIMPLE IRA, additional amounts may be contributed as permitted by the Code and the terms of the employer’s plan. Generally, rollovers and direct transfers will not be subject to such limitations. Purchase payments (except for rollovers and direct transfers) are generally not permitted after the calendar year in which you attain age 69 ¹/2.

a. Individual Retirement Annuities

Section 408 of the Code permits eligible individuals to contribute to an individual retirement program known as a traditional IRA. Under applicable limitations, certain amounts may be contributed to an IRA which will be deductible from the individual’s gross income. These IRAs are subject to limitations on eligibility, contributions, transferability and distributions. See IRS Publication 590 for additional details. Traditional IRAs include the SEP IRA and SIMPLE IRA. An employer can establish a SEP IRA or SIMPLE IRA for its employees. Under an employer’s SEP IRA or SIMPLE IRA, contributions for each eligible employee can be made under a contract issued as an IRA. Under certain conditions, distributions from other IRAs and other retirement plans may be rolled over or transferred on a tax deferred basis into an IRA. Sales of contracts for use with IRAs are subject to special requirements imposed by the Code, including the requirement that certain informational disclosure be given to persons desiring to establish an IRA. Purchasers of IRAs should obtain competent tax advice as to the tax treatment and suitability of such an investment.

b. Roth Individual Retirement Annuities

Section 408A of the Code permits eligible individuals to make nondeductible contributions to Roth IRAs. Section 408A includes limits on how much you may contribute to a Roth IRA and when distributions may commence. Qualified distributions from Roth IRAs are excluded from taxable gross income. “Qualified distributions” are distributions which (a) are made more than five years after the taxable year of the first contribution to a Roth IRA, and (b) meet any of the following conditions; (1) the annuity owner has reached age 59  ¹/2; (2) the distribution is paid to a beneficiary after the owner’s death; (3) the annuity owner is disabled; or (4) the distribution will be used for a first time home purchase. (Qualified distributions for first time home purchases may not exceed $10,000.) Non-qualified distributions are includable in taxable gross income only to the extent that they exceed the contributions made to the Roth IRA. The taxable portion of a non-qualified distribution may be subject to the 10% penalty tax.

You may convert a traditional IRA to a Roth IRA. You will be required to include the taxable portion of the conversion in your taxable gross income, but you will not be required to pay the 10% penalty tax. A special rule permits taxation of Roth IRA conversions made during the 2010 tax year to be split between 2011 and 2012. You may wish to consult a tax advisor before combining any converted amounts with any other Roth IRA contributions, including any other conversion amounts from other tax years.

2. The following describes contracts offered to participants of employer-sponsored retirement plans. Owners, annuitants and beneficiaries are cautioned that benefits under a retirement plan may be subject to the terms and conditions of the plan regardless of the terms and conditions of the contracts issued pursuant to the plan. Some retirement plans are subject to distribution and other requirements that are not incorporated into Symetra Life’s administrative procedures. Contract owners, participants and beneficiaries are responsible for determining that contributions, distributions and other transactions with respect to the contract comply with applicable law. Contracts issued in connection with retirement plans include special provisions that may restrict or modify the contract provisions and administrative services described in the prospectus. Generally, contracts issued pursuant to retirement plans are not transferable except upon surrender or annuitization. The tax rules regarding retirement plans are very complex and will have differing applications depending on individual facts and circumstances.

On July 6, 1983, the Supreme Court decided in Arizona Governing Committee v. Norris that optional annuity benefits provided under an employer’s deferred compensation plan could not, under Title VII of the Civil Rights Act of 1964, vary between men and women. The contracts sold by Symetra Life in connection with

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retirement plans will utilize annuity purchase rate tables which do not differentiate on the basis of sex. Such annuity purchase rate tables will also be available for use in connection with certain non-qualified deferred compensation plans.

a. Tax Sheltered Annuities

Section 403(b) of the Code permits the purchase of “Tax Sheltered Annuities” (“TSA”) by public schools and certain charitable, educational and scientific organizations described in Section 501(c)(3) of the Code. These qualifying employers may make contributions to the contracts for the benefit of their employees. Such contributions are not includable in the gross income of the employees until the employees receive distributions from the contracts. The amount of contributions to the TSA is limited to certain maximums imposed by the Code. Furthermore, the Code sets forth additional restrictions governing such items as transferability, distributions, nondiscrimination and withdrawals. (See “Tax Treatment of Withdrawals - Qualified Contracts” below.) Pursuant to new tax regulations, we generally are required to confirm, with your 403(b) plan sponsor or otherwise, that surrenders or partial withdrawals you request from a 403(b) contract comply with applicable tax requirements before we process your request. Any employee should obtain competent tax advice as to the tax treatment and suitability of such an investment.

b. Roth TSAs

Section 402A of the Code permits an employee to designate their contributions to their TSAs as Roth TSA contributions if Roth TSA contributions are permitted by the employer. Many of the federal rules pertaining to Roth TSAs have not yet been finalized. The IRS has not issued guidance regarding issues that may arise with respect to allocation of contract income, expenses, gains and losses. It has also not issued guidance with regards to the allocation of certain charges for guarantees under annuity contracts. Both you and your employer should consult their own tax and legal advisors prior to making or permitting contributions to be made to a Roth TSA. Roth TSA contributions are includable in gross income and are subject to the TSA limits discussed above. Qualified distributions from Roth TSAs are excluded from taxable gross income. “Qualified distributions” are distributions which (a) are made more than five years after the taxable year for which the employee first designated a contribution as a Roth TSA contribution, and (b) meet any of the following conditions: (1) the annuity owner has reached age 59 ¹/2; (2) the distribution is paid to a beneficiary after the owner’s death; or (3) the annuity owner is disabled. Non-qualified distributions are includable in taxable gross income only to the extent that they exceed the contributions made to the Roth TSA. The taxable portion of a non-qualified distribution may be subject to the 10% penalty tax.

c. Deferred Compensation Plans (457 Plans)

Section 457 of the Code permits governmental and certain other tax exempt employers to establish deferred compensation plans for the benefit of their employees. The Code establishes limitations and restrictions on eligibility, contributions and distributions. Under these plans, contributions made for the benefit of the employees will not be includable in the employees’ gross income until distributed from the plan. Generally, because contributions are on a before-tax basis, withdrawals are subject to income tax. Your employer may allow loans under governmental Section 457 plans. Special rules apply to deferred compensation plans. Owners should consult their own tax counsel or other tax adviser regarding any distributions.

Tax Treatment of Withdrawals - Qualified Contracts

In addition to ordinary income tax, Section 72(t) of the Code imposes a 10% penalty tax on the taxable portion of any distribution from certain retirement plans, including contracts issued and qualified under Code Sections 403(b) (Tax Sheltered Annuities and Roth Tax Sheltered annuities), 408 (Individual Retirement Annuities), and 408A (Roth Individual Retirement Annuities). To the extent amounts are not includable in gross income because they have been rolled over to an IRA or to another eligible plan, no tax penalty will be imposed.

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The tax penalty will not apply to the following distributions: (a) if distribution is made on or after the date on which the owner reaches age 59 ¹/2; (b) distributions following the death or disability of the owner (for this purpose disability is as defined in Section 72(m)(7) of the Code); (c) after separation from service, distributions that are part of substantially equal periodic payments made not less frequently than annually for the life (or life expectancy) of the owner or the joint lives (or joint life expectancies) of such owner and his or her designated beneficiary; (d) distributions made to the owner who has separated from service after he or she has attained age 55; (e) distributions made to the owner to the extent such distributions do not exceed the amount allowable as a deduction under Code Section 213 to the owner for amounts paid during the taxable year for medical care; (f) distributions made to an alternate payee pursuant to qualified domestic relations order; (g) distributions made to pay health insurance premiums for an unemployed owner; (h) distributions made to pay qualified higher education expenses; (i) distributions made to an owner for first home purchases; (j) distributions due to an IRS levy; (k) “qualified reservist distributions”, as defined by the Code; and (l) distributions to qualified public safety employees from a governmental defined benefit plan after attaining age 50 and separating from service. The exceptions stated in (d), and (f) above do not apply in the case of an IRA or Roth IRA. The exception stated in (c) above applies to an IRA and Roth IRA without the requirement that there be a separation from service. The exceptions stated in (g), (h), and (i) above do not apply in the case of a TSA or Roth TSA.

Generally, distributions from a retirement plan must commence no later than April 1st of the calendar year, following the year in which the employee attains age 70 ¹/2. Distributions from a TSA or Deferred Compensation Plan may, however, be deferred until actual retirement, if later. Such distributions (including distributions from Roth TSAs) must include the present value of any optional benefits you have purchased under the contract and must be over a period not exceeding the life expectancy of the individual or the joint lives or life expectancies of the individual and his or her designated beneficiary. If the required minimum distributions are not made, a 50% penalty tax is imposed as to the amount not distributed. Generally, if you die before required minimum distributions have begun, we must make payment of your entire interest by December 31^st of the year that is the fifth anniversary of your death or begin making payments over a period and in a manner allowed by the Code to your beneficiary by December 31^st of the year after your death. If your spouse is your beneficiary and your contract permits, your spouse may delay the start of required minimum distribution until December 31 of the year in which you would have reached age 70  ¹/2. Or, if your spouse is your sole beneficiary and the contract is an IRA, then he or she may elect to rollover the death proceeds into his or her own IRA (or a Roth IRA and pay tax on the taxable portion of the death proceeds) and treat the IRA (or Roth IRA) as his or her own. Your spouse may also be able to rollover the death proceeds into the spouse’s eligible retirement plan. Your plan may also offer non-spouse rollovers beginning in 2010. Contact your retirement plan for details.

Non-spouse beneficiary may be able to rollover death proceeds to inherited IRAs. If you die after required distributions have begun, payments of your entire remaining interest must be made in a manner and over a period as provided under the Code.

Roth IRAs are not subject to the required minimum distribution rule. Distributions from a Roth IRA may be deferred until the death of the owner.

A special rule permits taxation of Roth IRA conversions made during the 2010 tax year to be split between 2011 and 2012. You may wish to consult a tax advisor before combining any converted amounts with any other Roth IRA contributions, including any other conversion amounts from other tax years.

Tax Sheltered Annuities - Withdrawal Limitations

The Code limits the withdrawal of amounts attributable to contributions made pursuant to a salary reduction agreement (as defined in Section 403(b)(11) of the Code) to circumstances only when the owner: (1) attains age 59 ¹/2; (2) separates from service; (3) dies or becomes disabled (within the meaning of Section 72(m)(7) of the Code); (4) experiences a hardship; (5) is divorced and the distribution is permitted under a Qualified Domestic Relations Order; or (6) is a member of the National Guard or Reserves, is called to active duty and requests a qualified reservist distribution. Withdrawals for hardship are restricted to the portion of the owner’s Contract Value which represents contributions made by the owner and do not include any investment results. The limitations on withdrawals became effective on January 1, 1989 and apply only to salary reduction contributions made after December 31, 1988, to income attributable to such contributions and to income attributable to amounts held as of December 31, 1988. The limitations on withdrawals do not affect rollovers or transfers between certain retirement plans.

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In addition, for contracts issued on or after January 1, 2009, amounts attributable to employer contributions are subject to withdrawal limitations specified in the employer’s section 403(b) plan document.

Owners should consult their own tax counsel or other tax adviser regarding any distributions.

Income Tax Withholding

All distributions or any portion(s) thereof which are includable in the gross income of the owner are subject to federal income tax withholding. Generally, amounts are withheld from periodic payments at the same rate as wages and at the rate of 10% from non-periodic payments. However, the owner, in most cases, may elect not to have taxes withheld or to have withholding done at a different rate. Special withholding rules apply to United States citizens residing outside the United States and to non-resident aliens.

Certain distributions from retirement plans qualified under Section 403(b) or from governmental retirement plans qualified under Section 457, which are not directly rolled over to another eligible retirement plan or individual retirement account or individual retirement annuity, are subject to a mandatory 20% withholding for federal income tax. The 20% withholding requirement generally does not apply to: (a) a series of substantially equal payments made at least annually for the life or life expectancy of the participant or joint and last survivor expectancy of the participant and a designated beneficiary; (b) distributions for a specified period of 10 years or more; (c) distributions which are required minimum distributions; (d) the portion of distributions not includable in gross income (i.e. returns of after-tax contributions); (e) hardship distributions; or (f) corrective distributions. You should consult your own tax counsel or other tax adviser regarding income tax withholding.

Diversification

Section 817(h) of the Code imposes certain diversification standards on the underlying assets of variable annuity contracts. The Code provides that a variable annuity contract will not be treated as an annuity contract for any period (and any subsequent period) for which the investments are not, in accordance with regulations prescribed by the United States Treasury Department (“Treasury Department”), adequately diversified. Disqualification of the contract as an annuity contract would result in imposition of federal income tax to the owner with respect to earnings allocable to the contract prior to the receipt of payments under the contract. The Code contains a safe harbor provision which provides that annuity contracts such as the contracts meet the diversification requirements if, as of the end of each quarter, the underlying assets meet the diversification standards for a regulated investment company and no more than fifty-five percent (55%) of the total assets consist of cash, cash items, U.S. Government securities and securities of other regulated investment companies.

The Treasury Department has issued Regulations (Treas. Reg. 1.817-5), which establish diversification requirements for the portfolios underlying variable contracts such as those described in the prospectus. The Regulations amplify the diversification requirements for variable contracts set forth in the Code and provide an alternative to the safe harbor provision described above. Under the Regulations, an investment portfolio will be deemed adequately diversified if: (1) no more than 55% of the value of the total assets of the portfolio is represented by any one investment; (2) no more than 70% of the value of the total assets of the portfolio is represented by any two investments; (3) no more than 80% of the value of the total assets of the portfolio is represented by any three investments; and (4) no more than 90% of the value of the total assets of the portfolio is represented by any four investments.

The Code provides that, for purposes of determining whether or not the diversification standards imposed on the underlying assets of variable contracts by Section 817(h) of the Code have been met, “each United States government agency or instrumentality shall be treated as a separate issuer.”

Symetra Life intends that all Sub-accounts underlying the contracts will be managed in such a manner as to comply with these diversification requirements.

The Treasury Department has indicated that the diversification Regulations do not provide guidance regarding the circumstances in which owner control of the investments of the Separate Account will cause the contract Owner to be treated as the owner of the assets of the Separate Account, thereby resulting in the loss of favorable tax treatment for the contract. If the contract Owner is deemed to have “investor control” over the underlying portfolios, then the contract Owner could be taxed currently on income and gains under the contract.

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The application of the investor control doctrine is subject to some uncertainty. The amount of owner control which may be exercised under the contract is different in some respects from the situations addressed in published rulings issued by the Internal Revenue Service in which it was held that the contract owner was not the owner of the assets of the separate account. It is unknown whether these differences, such as your ability to transfer among Sub-accounts or the number and type of Sub-accounts available, would cause you to be considered the owner of the assets of the Separate Account resulting in the imposition of federal income tax with respect to earnings allocable to the contract prior to receipt of payments under the contract.

In addition, in 2003 the IRS issued Revenue Ruling 2003-91 that indicates that if the number of underlying sub-accounts does not exceed 20, then the number of sub-accounts alone would not cause the contract owner to have investment control of the sub-account assets. The IRS also indicated that exceeding 20 investment options may be a factor, along with other factors, when determining whether a variable contract owner has investor control over the underlying contract assets. The revenue ruling did not indicate the number of investment options, or sub-accounts, if any, that would cause the contract owner to have investor control over the sub-account assets.

We believe that the design of our contracts and the relationship between our contracts and the Portfolios is such that the investor control doctrine should not apply. In the event any forthcoming guidance or ruling is considered to set forth a new position, such guidance or ruling will generally be applied only prospectively. However, if such ruling or guidance was not considered to set forth a new position, it may be applied retroactively resulting in the contract owner being retroactively determined to be the owner of the assets of the Separate Account.

Due to the uncertainty in this area, Symetra Life reserves the right to modify the contract in an attempt to maintain favorable tax treatment.

ANNUITY PROVISIONS

Annuity Unit Value

The value of an Annuity Unit for each Sub-account on any date varies to reflect the investment experience of the Sub-account, the assumed investment return of 4% on which the applicable Variable Annuity Purchase Rate Table is based, and the deduction for charges assessed and imposed by Symetra Life, including a mortality and expense risk charge, asset related administration charge, and, if applicable, a charge for premium taxes.

For any valuation period the value of an Annuity Unit is determined by multiplying the value of an Annuity Unit for each Sub-account, as of the immediately preceding valuation period by the Net Investment Factor(s) for the valuation period for which the value is being calculated, and dividing the result by the Assumed Investment Factor to adjust for the assumed investment return of 4% used in calculating the applicable Variable Annuity Purchase Rate Table.

The Net Investment Factor is a number that represents the change in the Accumulation Unit value of a Sub-account on successive days when the NYSE is open for regular trading. The Net Investment Factor for any Sub-account for any valuation day is determined by taking the Accumulation Unit value of the Sub-account as of the current valuation day, and dividing it by the Accumulation Unit value for the preceding day. The Net Investment Factor will likely be different from the Assumed Investment Factor, and therefore the Annuity Unit value will usually increase or decrease.

The Assumed Investment Factor for a one day valuation period is 1.00010746. This factor neutralizes the assumed investment return of 4% in the Variable Annuity Purchase Rate Table in the contract.

Variable Annuity Payments

The amount of the first annuity payment is based on the annuity option selected, the annuity purchase rate, the age and sex of the Annuitant, the investment performance of the Sub-accounts you selected, and the Annuity Date. The amount of the first payment is the sum of the payments from each Sub-account. We use the Variable Annuity Purchase Rate Table to determine the variable annuity payment based on the value of each Sub-account. We determine the value (after deduction for premium taxes, if applicable) on the 15^th day of the preceding month. The Variable Annuity Purchase Rate Table is contained in the contract and is guaranteed for the duration of the contract.

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The number of Annuity Units attributed to a Sub-account is the amount of the first annuity payment attributable to that Sub-account, divided by the value of the applicable Annuity Unit for that Sub-account. This determination is made as of the 15th day of the month preceding the Annuity Date. The number of Annuity Units attributed to the variable annuity payment each month remains constant unless the owner changes Sub-account elections. The value of an Annuity Unit will usually increase or decrease from one month to the next.

The dollar amount of each variable annuity payment is the sum of the payments from each Sub-account, which are determined by multiplying the number of Annuity Units credited for that Sub-account by the Annuity Unit value of that Sub-account as of the 15th day of the month preceding the annuity payment. If the NYSE is closed on that date, the calculation will be made on the next Business Day. If premium taxes are required by state law, these taxes will be deducted before they annuity payment is calculated.

To illustrate the manner in which variable annuity payments are determined we have provided the following example. Item (4) in the example shows the applicable monthly payment rate (which varies depending on the Variable Annuity Purchase Rate Table used in the contract) for an annuitant with an adjusted age 63, where an owner has elected a variable life annuity with a guaranteed period of 10 years with the assumed investment return of 4%. (The “Life Annuity with Guaranteed Period” option is described in the prospectus).

(1)	Assumed number of Accumulation Units in a Sub-account on maturity date		25,000
(2)	Assumed value of an Accumulation Unit in a Sub-account at maturity	$	12.50
(3)	Cash value of contract at maturity, (1) x (2)	$	312,500
(4)	Consideration required to purchase $1 of monthly annuity from Variable Annuity Purchase Rate Table	$	200.20
(5)	Amount of first payment from a Sub-account, (3) divided by (4)	$	1,560.94
(6)	Assumed value of Annuity Unit in a Sub-account at maturity	$	13.00
(7)	Number of Annuity Units attributed to a Sub-account, (5) divided by (6)		120.072

The $312,500 value at maturity provides a first payment from the Sub-account of $1,560.94, and payments thereafter of the varying dollar value of 120.072 Annuity Units. The amount of subsequent payments from the Sub-account is determined by multiplying 120.072 units by the value of an Annuity Unit in the Sub-account on the applicable valuation date. For example, if that unit value is $13.25, the monthly payment from the Sub-account will be 120.072 multiplied by $13.25, or $1,590.95.

However, the value of the Annuity Unit depends on the investment experience of the Sub-account. Thus in the example above, if the Net Investment Factor for the following month was less than the assumed investment return of 4%, the Annuity Unit would decline in value. If the Annuity Unit value declined to $12.75 the succeeding monthly payment would then be 120.072 x $12.75, or $1,530.92.

For the sake of simplicity the foregoing example assumes that all of the Annuity Units are in one Sub-account. If there are Annuity Units in two or more Sub-accounts, the annuity payment from each Sub-account is calculated separately, in the manner illustrated, and the total monthly payment is the sum of the payments from the Sub-accounts.

Fixed Annuity Payments

The amount of fixed annuity payments under a life annuity remains constant and is determined by applying the value of the contract used to purchase fixed annuity payments, after deduction for premium taxes, if applicable, to the Fixed Annuity Purchase Rate Table contained in the contract. Symetra Life may substitute more favorable payment rates for the rates in the Fixed Annuity Purchase Rate Table on a non-discriminatory basis.

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FINANCIAL STATEMENTS

The statutory-basis financial statements and schedules of Symetra Life Insurance Company included herein should be considered only as bearing upon the ability of Symetra Life to meet its obligations under the contract. They should not be considered as bearing upon the investment experience of the Separate Account or its Sub-accounts.

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Symetra Separate Account C

Report of Independent Registered Public Accounting Firm

To the Board of Directors of Symetra Life Insurance Company and Participants of Symetra Separate Account C

We have audited the accompanying statements of assets and liabilities of Symetra Separate Account C (comprising, respectively, the AIM Capital Appreciation I, AIM Capital Appreciation II, AIM Capital Development Series I, AIM Capital Development Series II, AIM Global Healthcare, AIM Global Real Estate, AIM International Growth I, AIM International Growth II, AIM Mid Cap Core Equity II, AIM Small Cap Equity II, American Century Balanced, American Century Inflation Protection II, American Century International, American Century International II, American Century Large Company Value II, American Century Ultra I, American Century Ultra II, American Century Value, American Funds AMCAP, American Funds American Balanced, American Funds American High-Income Trust, American Funds Capital World Bond, American Funds EuroPacific Growth, American Funds The Growth Fund of America, American Funds The Investment Company of America, American Funds New Perspective, American Funds Washington Mutual Investors, BlackRock Global Allocation III, BlackRock Global Growth III, BlackRock Large Cap Value III, Calvert Social Balanced, Calvert Social Equity, Calvert Social Mid-Cap Growth, Columbia Mid-Cap Value B, Columbia Mid-Cap Growth B, Columbia Small Company Growth B, Columbia Small Cap Value B, Dreyfus Appreciation, Dreyfus MidCap Stock, Dreyfus Quality Bond, Dreyfus Socially Responsible, Dreyfus Stock Index, Dreyfus Technology Growth, DWS Balanced VIP A, DWS Captial Growth VIP B, DWS Dreman Small Mid Cap Value B, DWS Global Opportunities B Share, DWS Global Thematic B Share, DWS International VIP A, DWS Small Cap Index A Share, Federated Capital Income, Federated High Income Bond, Federated International Equity, Fidelity Asset Manager, Fidelity Contrafund, Fidelity Contrafund II, Fidelity Equity Income, Fidelity Freedom Funds 2010 II, Fidelity Freedom Funds 2015 II, Fidelity Freedom Funds 2020 II, Fidelity Freedom Funds 2025 II, Fidelity Freedom Funds 2030 II, Fidelity Freedom Funds 2035 II, Fidelity Freedom Funds 2040 II, Fidelity Freedom Funds 2045 II, Fidelity Freedom Funds 2050 II, Fidelity Freedom Income Fund II, Fidelity Growth, Fidelity Growth & Income, Fidelity Growth Opportunities, Fidelity Index 500, Fidelity Mid-Cap Advisor II, Fidelity Money Market Fund, Fidelity Overseas II, Fidelity VIP Money Market Service Class, Franklin Flex Cap Growth Securities, Franklin Founding Allocation Fund Class II, Franklin Income Securities Fund Class II, Franklin Small Cap Value Fund II, Franklin Small-Mid Cap Growth II, Franklin U.S. Government II, Goldman Sachs Government Income, Ibbotson Aggressive Growth Class I, Ibbotson Aggressive Growth Class II, Ibbotson Balanced Class I, Ibbotson Balanced Class II, Ibbotson Conservative Class I, Ibbotson Conservative Class II, Ibbotson Growth Class I, Ibbotson Growth Class II, Ibbotson Income and Growth Class I, Ibbotson Income and Growth Class II, ING Global Resources, ING JP Morgan Emerging Markets Equity I, JP Morgan Insurance Trust International Equity I, JP Morgan Insurance Trust Mid Cap Value I, JP Morgan Insurance Trust U.S. Equity I, JP Morgan International Equity, JP Morgan Mid-Cap Value, JP Morgan US Large Cap Core Equity, Mutual Shares Securities, Neuberger Berman AMT Guardian Class S, Neuberger Berman AMT Mid Cap Growth Class S, Neuberger Berman AMT Regency Class S, Neuberger Berman Genesis Advisor, PIMCO All Asset Portfolio Advisor, PIMCO Commodity Fund Admin, PIMCO Total Return Portfolio Advisor, Pioneer Bond VCT Class I, Pioneer Emerging Markets VCT Class II, Pioneer Equity Income VCT Class II, Pioneer Fund VCT Class I, Pioneer Growth Opportunities VCT Class I, Pioneer High Yield VCT Class II, Pioneer Mid-Cap Value VCT Class I, Pioneer Money Market VCT Class I, Pioneer Real Estate VCT Class II, Pioneer Small-Cap Value VCT Class I, Pioneer Small-Cap Value VCT Class II, Pioneer Strategic Income VCT Class II, Summit Balance Index, Summit Barclays Aggregate Bond Index, Summit EAFE International Index F Class, Summit Nasdaq 100 Index, Summit Russell 2000 Small Cap Index F Class, Summit S&P Mid Cap 400 Index F Class, Templeton Developing Markets II, Templeton Global Bond Securities II, Templeton Growth Securities II, Vanguard Balanced, Vanguard High Yield Bond, Vanguard International, Vanguard Mid-Cap Index, Vanguard REIT Index, Vanguard Total Bond Market Index, Vanguard Total Stock Market Index, and Wanger USA sub-accounts) ("the Separate Account") as of December 31, 2009, and the related statements of operations for the year then ended, and the statements of changes in net assets for each of the two years in the period then ended. These financial statements are the responsibility of the Separate Account's management. Our responsibility is to express an opinion on these financial statements based on our audits.

We conducted our audits in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. We were not engaged to perform an audit of the Separate Account's internal control over financial reporting. Our audits included consideration of internal control over financial reporting as a basis for designing audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Separate Account's internal control over financial reporting. Accordingly, we express no such opinion. An audit also includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements, assessing the accounting principles used and significant estimates made by management, and evaluating the overall financial statement presentation. Our procedures included confirmation of securities owned as of December 31, 2009, by correspondence with the custodian. We believe that our audits provide a reasonable basis for our opinion.

In our opinion, the financial statements referred to above present fairly, in all material respects, the financial position of each of the respective sub-accounts constituting Symetra Separate Account C at December 31, 2009, the results of their operations for the year then ended, and the changes in their net assets for each of the two years in the period then ended, in conformity with U.S. generally accepted accounting principles.

/s/ Ernst & Young LLP

Seattle, Washington
April 29, 2010

1

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	AIM CAPITAL APPRECIATION I		AIM CAPITAL APPRECIATION II		AIM CAPITAL DEVELOPMENT SERIES I		AIM CAPITAL DEVELOPMENT SERIES II		AIM GLOBAL HEALTHCARE
ASSETS:
Investments in Underlying
Investments, at Cost	$	6,274,485	$	965,851	$	344,741	$	739,480	$	584,819
Shares Owned		249,157		44,001		24,334		58,516		34,126
Investments, at Fair Value	$	5,065,335	$	880,025	$	274,734	$	643,078	$	541,569
Total Assets		5,065,335		880,025		274,734		643,078		541,569
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	5,065,335	$	880,025	$	274,734	$	643,078	$	541,569
Spinnaker & Mainsail
Net Assets	$	4,873,775	$	830,348	$	230,669	$	598,385	$	441,169
Accumulation Units Outstanding		659,799		91,608		15,819		70,993		32,450
Accumulation Unit Value	$	7.387	$	9.064	$	14.581	$	8.428	$	13.595
Spinnaker Advisor
Net Assets	$	191,560	$	33,338	$	44,065	$	40,457	$	100,400
Accumulation Units Outstanding		25,976		3,688		3,032		4,810		7,409
Accumulation Unit Value	$	7.373	$	9.043	$	14.533	$	8.412	$	13.550
Spinnaker with EEB
Net Assets	$	-	$	-	$	-	$	2,595	$	-
Accumulation Units Outstanding		-		-		-		311		-
Accumulation Unit Value	$	-	$	-	$	-	$	8.380	$	-
Spinnaker with GMDB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker with EEB & GMDB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker Choice
Net Assets	$	-	$	13,947	$	-	$	1,641	$	-
Accumulation Units Outstanding		-		1,550		-		198		-
Accumulation Unit Value	$	-	$	9.000	$	-	$	8.380	$	-
Spinnaker Choice with EEB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker Choice with GMDB
Net Assets	$	-	$	2,392	$	-	$	-	$	-
Accumulation Units Outstanding		-		272		-		-		-
Accumulation Unit Value	$	-	$	8.917	$	-	$	-	$	-
Spinnaker Choice with EEB & GMDB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
2

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	AIM GLOBAL REAL ESTATE		AIM INTERNATIONAL GROWTH I		AIM INTERNATIONAL GROWTH II		AIM SMALL CAP EQUITY II		AMERICAN CENTURY BALANCED
ASSETS:
Investments in Underlying
Investments, at Cost	$	11,515,667	$	2,164,131	$	8,452,484	$	60,465	$	13,048,315
Shares Owned		663,204		82,942		327,516		5,670		1,998,003
Investments, at Fair Value	$	8,051,298	$	2,157,316	$	8,394,202	$	71,957	$	11,488,515
Total Assets		8,051,298		2,157,316		8,394,202		71,957		11,488,515
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	8,051,298	$	2,157,316	$	8,394,202	$	71,957	$	11,488,515
Spinnaker & Mainsail
Net Assets	$	6,696,861	$	1,878,781	$	7,439,940	$	50,207	$	9,283,947
Accumulation Units Outstanding		314,516		91,769		718,970		5,936		773,356
Accumulation Unit Value	$	21.292	$	20.473	$	10.348	$	8.459	$	12.004
Spinnaker Advisor
Net Assets	$	1,343,307	$	234,572	$	869,993	$	21,750	$	2,141,948
Accumulation Units Outstanding		65,825		11,496		84,233		2,574		207,465
Accumulation Unit Value	$	20.406	$	20.404	$	10.328	$	8.452	$	10.324
Spinnaker with EEB
Net Assets	$	-	$	-	$	2,693	$	-	$	5,424
Accumulation Units Outstanding		-		-		266		-		456
Accumulation Unit Value	$	-	$	-	$	10.289	$	-	$	11.903
Spinnaker with GMDB
Net Assets	$	465	$	-	$	7,186	$	-	$	332
Accumulation Units Outstanding		24		-		700		-		29
Accumulation Unit Value	$	21.051	$	-	$	10.270	$	-	$	11.869
Spinnaker with EEB & GMDB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker Choice
Net Assets	$	8,162	$	43,963	$	68,597			$	56,864
Accumulation Units Outstanding		570		2,877		6,666				5,130
Accumulation Unit Value	$	14.312	$	15.276	$	10.289			$	11.084
Spinnaker Choice with EEB
Net Assets	$	-	$	-	$	-			$	-
Accumulation Units Outstanding		-		-		-				-
Accumulation Unit Value	$	-	$	-	$	-			$	-
Spinnaker Choice with GMDB
Net Assets	$	2,503	$	-	$	5,793			$	-
Accumulation Units Outstanding		177		-		565				-
Accumulation Unit Value	$	14.151	$	-	$	10.211			$	-
Spinnaker Choice with EEB & GMDB
Net Assets	$	-	$	-	$	-			$	-
Accumulation Units Outstanding		-		-		-				-
Accumulation Unit Value	$	-	$	-	$	-			$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
3

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	AMERICAN CENTURY INFLATION PROTECTION II		AMERICAN CENTURY INTERNATIONAL		AMERICAN CENTURY LARGE COMPANY VALUE II		AMERICAN CENTURY ULTRA I		AMERICAN CENTURY ULTRA II
ASSETS:
Investments in Underlying
Investments, at Cost	$	4,659,067	$	13,155,623	$	470,391	$	480,071	$	114,027
Shares Owned		446,142		1,484,121		54,501		52,710		14,165
Investments, at Fair Value	$	4,787,088	$	11,472,255	$	469,802	$	428,016	$	113,879
Total Assets		4,787,088		11,472,255		469,802		428,016		113,879
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	4,787,088	$	11,472,255	$	469,802	$	428,016	$	113,879
Spinnaker & Mainsail
Net Assets	$	3,552,041	$	10,356,957	$	268,979	$	384,689	$	109,160
Accumulation Units Outstanding		313,107		1,078,617		29,480		33,967		11,801
Accumulation Unit Value	$	11.346	$	9.602	$	9.124	$	11.325	$	9.251
Spinnaker Advisor
Net Assets	$	1,176,390	$	1,069,940	$	117,700	$	34,181	$	4,719
Accumulation Units Outstanding		103,955		137,958		12,930		3,028		510
Accumulation Unit Value	$	11.320	$	7.755	$	9.103	$	11.287	$	9.238
Spinnaker with EEB
Net Assets	$	-	$	9,509	$	-	$	2,188	$	-
Accumulation Units Outstanding		-		999		-		195		-
Accumulation Unit Value	$	-	$	9.520	$	-	$	11.229	$	-
Spinnaker with GMDB
Net Assets	$	-	$	55	$	1,184	$	-	$	-
Accumulation Units Outstanding		-		6		134		-		-
Accumulation Unit Value	$	-	$	9.493	$	9.039	$	-	$	-
Spinnaker with EEB & GMDB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker Choice
Net Assets	$	58,657	$	35,794	$	81,939	$	1,728	$	-
Accumulation Units Outstanding		5,207		2,797		9,044		187		-
Accumulation Unit Value	$	11.267	$	12.796	$	9.060	$	9.266	$	-
Spinnaker Choice with EEB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker Choice with GMDB
Net Assets	$	-	$	-	$	-	$	5,230	$	-
Accumulation Units Outstanding		-		-		-		571		-
Accumulation Unit Value	$	-	$	-	$	-	$	9.162	$	-
Spinnaker Choice with EEB & GMDB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
4

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	AMERICAN CENTURY VALUE		DREYFUS APPRECIATION		DREYFUS MIDCAP STOCK		DREYFUS QUALITY BOND		DREYFUS SOCIALLY RESPONSIBLE
ASSETS:
Investments in Underlying
Investments, at Cost	$	4,525,790	$	5,061,098	$	16,283,551	$	5,472,437	$	3,397,475
Shares Owned		734,760		144,918		1,178,615		498,567		126,956
Investments, at Fair Value	$	3,879,529	$	4,550,443	$	12,328,303	$	5,524,111	$	3,333,839
Total Assets		3,879,529		4,550,443		12,328,303		5,524,111		3,333,839
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	3,879,529	$	4,550,443	$	12,328,303	$	5,524,111	$	3,333,839
Spinnaker & Mainsail
Net Assets	$	3,548,099	$	3,566,623	$	9,717,469	$	4,327,352	$	2,903,582
Accumulation Units Outstanding		294,076		380,664		886,723		298,365		474,717
Accumulation Unit Value	$	12.065	$	9.369	$	10.959	$	14.503	$	6.116
Spinnaker Advisor
Net Assets	$	320,448	$	963,418	$	2,576,591	$	1,196,759	$	412,528
Accumulation Units Outstanding		26,662		107,809		254,419		85,399		71,740
Accumulation Unit Value	$	12.019	$	8.933	$	10.127	$	14.014	$	5.750
Spinnaker with EEB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker with GMDB
Net Assets	$	-	$	2,000	$	301	$	-	$	-
Accumulation Units Outstanding		-		223		30		-		-
Accumulation Unit Value	$	-	$	9.263	$	10.835	$	-	$	-
Spinnaker with EEB & GMDB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker Choice
Net Assets	$	10,982	$	18,402	$	33,942	$	-	$	17,729
Accumulation Units Outstanding		1,047		1,716		3,359		-		1,709
Accumulation Unit Value	$	10.485	$	10.707	$	10.105	$	-	$	10.374
Spinnaker Choice with EEB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker Choice with GMDB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker Choice with EEB & GMDB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
5

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	DREYFUS STOCK INDEX		DREYFUS TECHNOLOGY GROWTH		DWS BALANCED VIP A		DWS CAPITAL GROWTH VIP B		DWS GLOBAL OPPORTUNITIES B SHARE
ASSETS:
Investments in Underlying
Investments, at Cost	$	16,369,531	$	2,787,236	$	14,129,991	$	1,304,460	$	54,231
Shares Owned		540,997		310,692		609,941		90,069		5,147
Investments, at Fair Value	$	14,249,828	$	3,103,812	$	12,515,968	$	1,518,564	$	57,196
Total Assets		14,249,828		3,103,812		12,515,968		1,518,564		57,196
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	14,249,828	$	3,103,812	$	12,515,968	$	1,518,564	$	57,196
Spinnaker & Mainsail
Net Assets	$	10,602,459	$	2,384,397	$	11,302,343	$	1,335,761	$	41,569
Accumulation Units Outstanding		864,042		586,599		526,299		158,352		5,398
Accumulation Unit Value	$	12.270	$	4.065	$	21.475	$	8.435	$	7.700
Spinnaker Advisor
Net Assets	$	3,553,621	$	719,415	$	1,213,625	$	182,803	$	15,627
Accumulation Units Outstanding		290,567		195,329		135,687		21,689		2,032
Accumulation Unit Value	$	12.230	$	3.683	$	8.944	$	8.428	$	7.694
Spinnaker with EEB
Net Assets	$	7,721	$	-			$	-	$	-
Accumulation Units Outstanding		637		-				-		-
Accumulation Unit Value	$	12.166	$	-			$	-	$	-
Spinnaker with GMDB
Net Assets	$	2,162	$	-			$	-	$	-
Accumulation Units Outstanding		182		-				-		-
Accumulation Unit Value	$	12.132	$	-			$	-	$	-
Spinnaker with EEB & GMDB
Net Assets	$	-	$	-			$	-	$	-
Accumulation Units Outstanding		-		-				-		-
Accumulation Unit Value	$	-	$	-			$	-	$	-
Spinnaker Choice
Net Assets	$	79,039	$	-
Accumulation Units Outstanding		7,881		-
Accumulation Unit Value	$	10.030	$	-
Spinnaker Choice with EEB
Net Assets	$	-	$	-
Accumulation Units Outstanding		-		-
Accumulation Unit Value	$	-	$	-
Spinnaker Choice with GMDB
Net Assets	$	4,826	$	-
Accumulation Units Outstanding		487		-
Accumulation Unit Value	$	9.917	$	-
Spinnaker Choice with EEB & GMDB
Net Assets	$	-	$	-
Accumulation Units Outstanding		-		-
Accumulation Unit Value	$	-	$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
6

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	DWS GLOBAL THEMATIC B SHARE		DWS INTERNATIONAL VIP A		DWS SMALL CAP INDEX A SHARE		FEDERATED CAPITAL INCOME		FEDERATED HIGH INCOME BOND
ASSETS:
Investments in Underlying
Investments, at Cost	$	25,089	$	6,766,550	$	53,603	$	1,802,424	$	3,453,500
Shares Owned		3,625		564,830		5,927		189,333		505,659
Investments, at Fair Value	$	29,906	$	4,665,493	$	58,666	$	1,641,522	$	3,372,759
Total Assets		29,906		4,665,493		58,666		1,641,522		3,372,759
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	29,906	$	4,665,493	$	58,666	$	1,641,522	$	3,372,759
Spinnaker & Mainsail
Net Assets	$	29,906	$	4,597,309			$	1,570,918	$	2,846,101
Accumulation Units Outstanding		3,975		278,102				102,348		155,879
Accumulation Unit Value	$	7.523	$	16.531			$	15.345	$	18.257
Spinnaker Advisor
Net Assets	$	-	$	68,184			$	46,375	$	513,827
Accumulation Units Outstanding		-		8,783				5,069		34,396
Accumulation Unit Value	$	-	$	7.763			$	9.148	$	14.935
Spinnaker with EEB
Net Assets	$	-	$	-			$	-	$	-
Accumulation Units Outstanding		-		-				-		-
Accumulation Unit Value	$	-	$	-			$	-	$	-
Spinnaker with GMDB
Net Assets	$	-	$	-			$	-	$	-
Accumulation Units Outstanding		-		-				-		-
Accumulation Unit Value	$	-	$	-			$	-	$	-
Spinnaker with EEB & GMDB
Net Assets	$	-	$	-			$	-	$	-
Accumulation Units Outstanding		-		-				-		-
Accumulation Unit Value	$	-	$	-			$	-	$	-
Spinnaker Choice
Net Assets							$	24,229	$	12,831
Accumulation Units Outstanding								1,838		973
Accumulation Unit Value							$	13.179	$	13.185
Spinnaker Choice with EEB
Net Assets							$	-	$	-
Accumulation Units Outstanding								-		-
Accumulation Unit Value							$	-	$	-
Spinnaker Choice with GMDB
Net Assets							$	-	$	-
Accumulation Units Outstanding								-		-
Accumulation Unit Value							$	-	$	-
Spinnaker Choice with EEB & GMDB
Net Assets							$	-	$	-
Accumulation Units Outstanding								-		-
Accumulation Unit Value							$	-	$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
7

Symetra Separate Account C

Statements of Assets and Liabilities (continued)

As of December 31, 2009

	Sub-Accounts
	DWS GLOBAL THEMATIC B SHARE	DWS INTERNATIONAL VIP A	DWS SMALL CAP INDEX A SHARE		FEDERATED CAPITAL INCOME	FEDERATED HIGH INCOME BOND
Focus Tier I
Net Assets			$	6,215
Accumulation Units Outstanding				713
Accumulation Unit Value			$	8.711
Focus Tier II
Net Assets			$	44,877
Accumulation Units Outstanding				5,148
Accumulation Unit Value			$	8.718
Focus Tier III
Net Assets			$	-
Accumulation Units Outstanding				-
Accumulation Unit Value			$	-
Focus Tier IV
Net Assets			$	-
Accumulation Units Outstanding				-
Accumulation Unit Value			$	-
Focus Tier V
Net Assets			$	-
Accumulation Units Outstanding				-
Accumulation Unit Value			$	-
Focus Tier I with GMDB
Net Assets			$	-
Accumulation Units Outstanding				-
Accumulation Unit Value			$	-
Focus Tier II with GMDB
Net Assets			$	7,574
Accumulation Units Outstanding				870
Accumulation Unit Value			$	8.704
Focus Tier III with GMDB
Net Assets			$	-
Accumulation Units Outstanding				-
Accumulation Unit Value			$	-
Focus Tier IV with GMDB
Net Assets			$	-
Accumulation Units Outstanding				-
Accumulation Unit Value			$	-
Focus Tier V with GMDB
Net Assets			$	-
Accumulation Units Outstanding				-
Accumulation Unit Value			$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
8

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	FEDERATED INTERNATIONAL EQUITY		FIDELITY ASSET MANAGER		FIDELITY CONTRAFUND		FIDELITY EQUITY INCOME		FIDELITY FREEDOM FUNDS 2010 II
ASSETS:
Investments in Underlying
Investments, at Cost	$	1,205,910	$	528,431	$	36,615,120	$	10,369,250	$	97,369
Shares Owned		71,795		36,612		1,418,405		490,820		10,207
Investments, at Fair Value	$	987,910	$	475,953	$	29,247,525	$	8,250,718	$	99,412
Total Assets		987,910		475,953		29,247,525		8,250,718		99,412
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	987,910	$	475,953	$	29,247,525	$	8,250,718	$	99,412
Spinnaker & Mainsail
Net Assets	$	987,910	$	358,474	$	26,874,394	$	7,259,933	$	52,054
Accumulation Units Outstanding		60,674		27,851		1,687,798		582,965		5,611
Accumulation Unit Value	$	16.282	$	12.871	$	15.922	$	12.453	$	9.276
Spinnaker Advisor
Net Assets			$	117,479	$	2,129,887	$	940,964	$	47,358
Accumulation Units Outstanding				9,158		135,376		75,810		5,109
Accumulation Unit Value			$	12.828	$	15.733	$	12.412	$	9.269
Spinnaker with EEB
Net Assets			$	-	$	-	$	3,495	$	-
Accumulation Units Outstanding				-		-		284		-
Accumulation Unit Value			$	-	$	-	$	12.348	$	-
Spinnaker with GMDB
Net Assets			$	-	$	3,087	$	205	$	-
Accumulation Units Outstanding				-		197		19		-
Accumulation Unit Value			$	-	$	15.743	$	12.313	$	-
Spinnaker with EEB & GMDB
Net Assets			$	-	$	-	$	-	$	-
Accumulation Units Outstanding				-		-		-		-
Accumulation Unit Value			$	-	$	-	$	-	$	-
Spinnaker Choice
Net Assets			$	-	$	236,507	$	46,121
Accumulation Units Outstanding				-		19,201		4,708
Accumulation Unit Value			$	-	$	12.317	$	9.796
Spinnaker Choice with EEB
Net Assets			$	-	$	-	$	-
Accumulation Units Outstanding				-		-		-
Accumulation Unit Value			$	-	$	-	$	-
Spinnaker Choice with GMDB
Net Assets			$	-	$	3,650	$	-
Accumulation Units Outstanding				-		301		-
Accumulation Unit Value			$	-	$	12.178	$	-
Spinnaker Choice with EEB & GMDB
Net Assets			$	-	$	-	$	-
Accumulation Units Outstanding				-		-		-
Accumulation Unit Value			$	-	$	-	$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
9

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	FIDELITY FREEDOM FUNDS 2015 II		FIDELITY FREEDOM FUNDS 2020 II		FIDELITY FREEDOM FUNDS 2025 II		FIDELITY FREEDOM FUNDS 2030 II		FIDELITY FREEDOM INCOME FUND II
ASSETS:
Investments in Underlying
Investments, at Cost	$	61,173	$	473,203	$	213,182	$	118,858	$	54,029
Shares Owned		6,791		56,161		26,721		15,118		5,273
Investments, at Fair Value	$	66,135	$	532,403	$	247,709	$	136,070	$	52,581
Total Assets		66,135		532,403		247,709		136,070		52,581
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	66,135	$	532,403	$	247,709	$	136,070	$	52,581
Spinnaker & Mainsail
Net Assets	$	51,906	$	523,163	$	123,883	$	87,046	$	48,742
Accumulation Units Outstanding		5,681		59,721		14,309		10,484		4,856
Accumulation Unit Value	$	9.136	$	8.760	$	8.658	$	8.302	$	10.036
Spinnaker Advisor
Net Assets	$	14,229	$	9,240	$	123,826	$	49,024	$	3,839
Accumulation Units Outstanding		1,559		1,056		14,314		5,910		383
Accumulation Unit Value	$	9.129	$	8.753	$	8.650	$	8.295	$	10.028
Spinnaker with EEB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker with GMDB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker with EEB & GMDB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker Choice
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker Choice with EEB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker Choice with GMDB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker Choice with EEB & GMDB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
10

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	FIDELITY GROWTH		FIDELITY GROWTH & INCOME		FIDELITY GROWTH OPPORTUNITIES		FIDELITY INDEX 500		FIDELITY MID-CAP ADVISOR II
ASSETS:
Investments in Underlying
Investments, at Cost	$	14,296,708	$	8,355,847	$	3,661,471	$	308,349	$	8,419,861
Shares Owned		417,575		624,117		211,748		2,799		313,729
Investments, at Fair Value	$	12,543,911	$	6,908,971	$	3,072,473	$	334,746	$	7,874,558
Total Assets		12,543,911		6,908,971		3,072,473		334,746		7,874,558
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	12,543,911	$	6,908,971	$	3,072,473	$	334,746	$	7,874,558
Spinnaker & Mainsail
Net Assets	$	10,956,116	$	5,611,489	$	2,912,483			$	6,376,168
Accumulation Units Outstanding		1,877,698		639,690		404,328				505,863
Accumulation Unit Value	$	5.835	$	8.772	$	7.203			$	12.604
Spinnaker Advisor
Net Assets	$	1,571,989	$	1,268,253	$	159,990			$	1,430,185
Accumulation Units Outstanding		285,036		150,163		24,991				113,732
Accumulation Unit Value	$	5.515	$	8.446	$	6.401			$	12.575
Spinnaker with EEB
Net Assets	$	-	$	-					$	-
Accumulation Units Outstanding		-		-						-
Accumulation Unit Value	$	-	$	-					$	-
Spinnaker with GMDB
Net Assets	$	2,289	$	168					$	996
Accumulation Units Outstanding		405		20						84
Accumulation Unit Value	$	5.769	$	8.673					$	12.487
Spinnaker with EEB & GMDB
Net Assets	$	-	$	-					$	-
Accumulation Units Outstanding		-		-						-
Accumulation Unit Value	$	-	$	-					$	-
Spinnaker Choice
Net Assets	$	8,477	$	29,061					$	67,209
Accumulation Units Outstanding		914		2,941						5,370
Accumulation Unit Value	$	9.295	$	9.880					$	12.516
Spinnaker Choice with EEB
Net Assets	$	-	$	-					$	-
Accumulation Units Outstanding		-		-						-
Accumulation Unit Value	$	-	$	-					$	-
Spinnaker Choice with GMDB
Net Assets	$	5,040	$	-					$	-
Accumulation Units Outstanding		549		-						-
Accumulation Unit Value	$	9.190	$	-					$	-
Spinnaker Choice with EEB & GMDB
Net Assets	$	-	$	-					$	-
Accumulation Units Outstanding		-		-						-
Accumulation Unit Value	$	-	$	-					$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
11

Symetra Separate Account C

Statements of Assets and Liabilities (continued)

As of December 31, 2009

	Sub-Accounts
	FIDELITY GROWTH	FIDELITY GROWTH & INCOME	FIDELITY GROWTH OPPORTUNITIES	FIDELITY INDEX 500		FIDELITY MID-CAP ADVISOR II
Focus Tier I
Net Assets				$	108,651
Accumulation Units Outstanding					14,631
Accumulation Unit Value				$	7.429
Focus Tier II
Net Assets				$	79,995
Accumulation Units Outstanding					10,756
Accumulation Unit Value				$	7.439
Focus Tier III
Net Assets				$	-
Accumulation Units Outstanding					-
Accumulation Unit Value				$	-
Focus Tier IV
Net Assets				$	-
Accumulation Units Outstanding					-
Accumulation Unit Value				$	-
Focus Tier V
Net Assets				$	-
Accumulation Units Outstanding					-
Accumulation Unit Value				$	-
Focus Tier I with GMDB
Net Assets				$	-
Accumulation Units Outstanding					-
Accumulation Unit Value				$	-
Focus Tier II with GMDB
Net Assets				$	146,100
Accumulation Units Outstanding					19,698
Accumulation Unit Value				$	7.419
Focus Tier III with GMDB
Net Assets				$	-
Accumulation Units Outstanding					-
Accumulation Unit Value				$	-
Focus Tier IV with GMDB
Net Assets				$	-
Accumulation Units Outstanding					-
Accumulation Unit Value				$	-
Focus Tier V with GMDB
Net Assets				$	-
Accumulation Units Outstanding					-
Accumulation Unit Value				$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
12

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	FIDELITY MONEY MARKET FUND		FIDELITY OVERSEAS II		FIDELITY VIP MONEY MARKET SERVICE CLASS		FRANKLIN FLEX CAP GROWTH SECURITIES		FRANKLIN FOUNDING ALLOCATION FUND CLASS II
ASSETS:
Investments in Underlying
Investments, at Cost	$	2,313,343	$	114,963	$	13,096,560	$	248,376	$	335,990
Shares Owned		2,313,343		7,180		13,096,560		24,258		50,544
Investments, at Fair Value	$	2,313,343	$	107,139	$	13,096,560	$	265,167	$	360,879
Total Assets		2,313,343		107,139		13,096,560		265,167		360,879
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	2,313,343	$	107,139	$	13,096,560	$	265,167	$	360,879
Spinnaker & Mainsail
Net Assets			$	79,269	$	9,437,656	$	257,262	$	317,255
Accumulation Units Outstanding				10,887		868,587		23,397		37,126
Accumulation Unit Value			$	7.281	$	10.866	$	10.996	$	8.545
Spinnaker Advisor
Net Assets			$	27,870	$	3,516,840	$	2,817	$	43,624
Accumulation Units Outstanding				3,830		324,504		256		5,109
Accumulation Unit Value			$	7.275	$	10.839	$	10.970	$	8.538
Spinnaker with EEB
Net Assets			$	-	$	1,860	$	-	$	-
Accumulation Units Outstanding				-		172		-		-
Accumulation Unit Value			$	-	$	10.784	$	-	$	-
Spinnaker with GMDB
Net Assets			$	-	$	3,688	$	-	$	-
Accumulation Units Outstanding				-		343		-		-
Accumulation Unit Value			$	-	$	10.756	$	-	$	-
Spinnaker with EEB & GMDB
Net Assets			$	-	$	-	$	-	$	-
Accumulation Units Outstanding				-		-		-		-
Accumulation Unit Value			$	-	$	-	$	-	$	-
Spinnaker Choice
Net Assets					$	136,516	$	1,436
Accumulation Units Outstanding						12,653		133
Accumulation Unit Value					$	10.784	$	10.919
Spinnaker Choice with EEB
Net Assets					$	-	$	-
Accumulation Units Outstanding						-		-
Accumulation Unit Value					$	-	$	-
Spinnaker Choice with GMDB
Net Assets					$	-	$	3,652
Accumulation Units Outstanding						-		339
Accumulation Unit Value					$	-	$	10.817
Spinnaker Choice with EEB & GMDB
Net Assets					$	-	$	-
Accumulation Units Outstanding						-		-
Accumulation Unit Value					$	-	$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
13

Symetra Separate Account C

Statements of Assets and Liabilities (continued)

As of December 31, 2009

	Sub-Accounts
	FIDELITY MONEY MARKET FUND		FIDELITY OVERSEAS II	FIDELITY VIP MONEY MARKET SERVICE CLASS	FRANKLIN FLEX CAP GROWTH SECURITIES	FRANKLIN FOUNDING ALLOCATION FUND CLASS II
Focus Tier I
Net Assets	$	1,466,211
Accumulation Units Outstanding		142,108
Accumulation Unit Value	$	10.318
Focus Tier II
Net Assets	$	401,297
Accumulation Units Outstanding		38,846
Accumulation Unit Value	$	10.331
Focus Tier III
Net Assets	$	265,051
Accumulation Units Outstanding		25,590
Accumulation Unit Value	$	10.358
Focus Tier IV
Net Assets	$	-
Accumulation Units Outstanding		-
Accumulation Unit Value	$	-
Focus Tier V
Net Assets	$	-
Accumulation Units Outstanding		-
Accumulation Unit Value	$	-
Focus Tier I with GMDB
Net Assets	$	103,398
Accumulation Units Outstanding		10,047
Accumulation Unit Value	$	10.291
Focus Tier II with GMDB
Net Assets	$	77,386
Accumulation Units Outstanding		7,510
Accumulation Unit Value	$	10.304
Focus Tier III with GMDB
Net Assets	$	-
Accumulation Units Outstanding		-
Accumulation Unit Value	$	-
Focus Tier IV with GMDB
Net Assets	$	-
Accumulation Units Outstanding		-
Accumulation Unit Value	$	-
Focus Tier V with GMDB
Net Assets	$	-
Accumulation Units Outstanding		-
Accumulation Unit Value	$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
14

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	FRANKLIN INCOME SECURITIES FUND CLASS II		FRANKLIN SMALL CAP VALUE FUND II		FRANKLIN SMALL-MID CAP GROWTH II		FRANKLIN U.S. GOVERNMENT II		IBBOTSON AGGRESSIVE GROWTH CLASS I
ASSETS:
Investments in Underlying
Investments, at Cost	$	6,773,327	$	6,110,187	$	5,738,935	$	17,094,867	$	322,871
Shares Owned		435,745		484,626		291,859		1,354,559		43,545
Investments, at Fair Value	$	6,152,725	$	6,188,664	$	4,923,658	$	17,433,171	$	352,275
Total Assets		6,152,725		6,188,664		4,923,658		17,433,171		352,275
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	6,152,725	$	6,188,664	$	4,923,658	$	17,433,171	$	352,275
Spinnaker & Mainsail
Net Assets	$	5,155,877	$	5,081,373	$	4,416,296	$	11,407,489
Accumulation Units Outstanding		453,416		476,485		612,651		757,557
Accumulation Unit Value	$	11.371	$	10.664	$	7.208	$	15.058
Spinnaker Advisor
Net Assets	$	883,943	$	1,071,257	$	492,239	$	5,439,571
Accumulation Units Outstanding		77,933		100,707		74,671		375,668
Accumulation Unit Value	$	11.342	$	10.639	$	6.592	$	14.480
Spinnaker with EEB
Net Assets	$	-	$	-	$	-	$	9,277
Accumulation Units Outstanding		-		-		-		622
Accumulation Unit Value	$	-	$	-	$	-	$	14.931
Spinnaker with GMDB
Net Assets	$	8,444	$	2,467	$	-	$	-
Accumulation Units Outstanding		751		236		-		-
Accumulation Unit Value	$	11.256	$	10.565	$	-	$	-
Spinnaker with EEB & GMDB
Net Assets	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-
Spinnaker Choice
Net Assets	$	92,929	$	33,567	$	15,123	$	576,834
Accumulation Units Outstanding		8,234		3,170		1,450		48,216
Accumulation Unit Value	$	11.285	$	10.590	$	10.434	$	11.964
Spinnaker Choice with EEB
Net Assets	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-
Spinnaker Choice with GMDB
Net Assets	$	11,532	$	-	$	-	$	-
Accumulation Units Outstanding		1,033		-		-		-
Accumulation Unit Value	$	11.171	$	-	$	-	$	-
Spinnaker Choice with EEB & GMDB
Net Assets	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
15

Symetra Separate Account C

Statements of Assets and Liabilities (continued)

As of December 31, 2009

	Sub-Accounts
	FRANKLIN INCOME SECURITIES FUND CLASS II	FRANKLIN SMALL CAP VALUE FUND II	FRANKLIN SMALL-MID CAP GROWTH II	FRANKLIN U.S. GOVERNMENT II	IBBOTSON AGGRESSIVE GROWTH CLASS I
Focus Tier I
Net Assets					$	287,809
Accumulation Units Outstanding						37,714
Accumulation Unit Value					$	7.631
Focus Tier II
Net Assets					$	8,832
Accumulation Units Outstanding						1,156
Accumulation Unit Value					$	7.641
Focus Tier III
Net Assets					$	55,634
Accumulation Units Outstanding						7,262
Accumulation Unit Value					$	7.661
Focus Tier IV
Net Assets					$	-
Accumulation Units Outstanding						-
Accumulation Unit Value					$	-
Focus Tier V
Net Assets					$	-
Accumulation Units Outstanding						-
Accumulation Unit Value					$	-
Focus Tier I with GMDB
Net Assets					$	-
Accumulation Units Outstanding						-
Accumulation Unit Value					$	-
Focus Tier II with GMDB
Net Assets					$	-
Accumulation Units Outstanding						-
Accumulation Unit Value					$	-
Focus Tier III with GMDB
Net Assets					$	-
Accumulation Units Outstanding						-
Accumulation Unit Value					$	-
Focus Tier IV with GMDB
Net Assets					$	-
Accumulation Units Outstanding						-
Accumulation Unit Value					$	-
Focus Tier V with GMDB
Net Assets					$	-
Accumulation Units Outstanding						-
Accumulation Unit Value					$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
16

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	IBBOTSON AGGRESSIVE GROWTH CLASS II		IBBOTSON BALANCED CLASS I		IBBOTSON BALANCED CLASS II		IBBOTSON CONSERVATIVE CLASS I		IBBOTSON CONSERVATIVE CLASS II
ASSETS:
Investments in Underlying
Investments, at Cost	$	1,721,329	$	1,153,134	$	3,102,034	$	159,195	$	515,356
Shares Owned		238,027		132,084		388,737		15,455		52,853
Investments, at Fair Value	$	1,918,495	$	1,199,317	$	3,564,722	$	162,894	$	557,075
Total Assets		1,918,495		1,199,317		3,564,722		162,894		557,075
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	1,918,495	$	1,199,317	$	3,564,722	$	162,894	$	557,075
Spinnaker & Mainsail
Net Assets	$	1,896,121			$	3,168,358			$	265,858
Accumulation Units Outstanding		230,416				352,033				26,928
Accumulation Unit Value	$	8.230			$	9.001			$	9.873
Spinnaker Advisor
Net Assets	$	22,374			$	396,364			$	291,217
Accumulation Units Outstanding		2,721				44,075				29,519
Accumulation Unit Value	$	8.223			$	8.993			$	9.865
Spinnaker with EEB
Net Assets	$	-			$	-			$	-
Accumulation Units Outstanding		-				-				-
Accumulation Unit Value	$	-			$	-			$	-
Spinnaker with GMDB
Net Assets	$	-			$	-			$	-
Accumulation Units Outstanding		-				-				-
Accumulation Unit Value	$	-			$	-			$	-
Spinnaker with EEB & GMDB
Net Assets	$	-			$	-			$	-
Accumulation Units Outstanding		-				-				-
Accumulation Unit Value	$	-			$	-			$	-
Spinnaker Choice
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker Choice with EEB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker Choice with GMDB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker Choice with EEB & GMDB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
17

Symetra Separate Account C

Statements of Assets and Liabilities (continued)

As of December 31, 2009

	Sub-Accounts
	IBBOTSON AGGRESSIVE GROWTH CLASS II	IBBOTSON BALANCED CLASS I		IBBOTSON BALANCED CLASS II	IBBOTSON CONSERVATIVE CLASS I		IBBOTSON CONSERVATIVE CLASS II
Focus Tier I
Net Assets		$	309,776		$	46,672
Accumulation Units Outstanding			35,160			4,524
Accumulation Unit Value		$	8.810		$	10.315
Focus Tier II
Net Assets		$	599,979		$	72,233
Accumulation Units Outstanding			68,011			6,992
Accumulation Unit Value		$	8.822		$	10.328
Focus Tier III
Net Assets		$	88,786		$	-
Accumulation Units Outstanding			10,038			-
Accumulation Unit Value		$	8.844		$	-
Focus Tier IV
Net Assets		$	-		$	-
Accumulation Units Outstanding			-			-
Accumulation Unit Value		$	-		$	-
Focus Tier V
Net Assets		$	-		$	-
Accumulation Units Outstanding			-			-
Accumulation Unit Value		$	-		$	-
Focus Tier I with GMDB
Net Assets		$	-		$	43,989
Accumulation Units Outstanding			-			4,275
Accumulation Unit Value		$	-		$	10.289
Focus Tier II with GMDB
Net Assets		$	200,776		$	-
Accumulation Units Outstanding			22,817			-
Accumulation Unit Value		$	8.799		$	-
Focus Tier III with GMDB
Net Assets		$	-		$	-
Accumulation Units Outstanding			-			-
Accumulation Unit Value		$	-		$	-
Focus Tier IV with GMDB
Net Assets		$	-		$	-
Accumulation Units Outstanding			-			-
Accumulation Unit Value		$	-		$	-
Focus Tier V with GMDB
Net Assets		$	-		$	-
Accumulation Units Outstanding			-			-
Accumulation Unit Value		$	-		$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
18

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	IBBOTSON GROWTH CLASS I		IBBOTSON GROWTH CLASS II		IBBOTSON INCOME AND GROWTH CLASS I		IBBOTSON INCOME AND GROWTH CLASS II		ING GLOBAL RESOURCES
ASSETS:
Investments in Underlying
Investments, at Cost	$	502,643	$	1,547,052	$	233,008	$	890,834	$	2,128,753
Shares Owned		57,970		208,823		23,313		97,321		97,130
Investments, at Fair Value	$	498,546	$	1,781,259	$	220,550	$	955,696	$	1,734,738
Total Assets		498,546		1,781,259		220,550		955,696		1,734,738
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	498,546	$	1,781,259	$	220,550	$	955,696	$	1,734,738
Spinnaker & Mainsail
Net Assets			$	1,667,251			$	764,349	$	1,668,174
Accumulation Units Outstanding				194,864				80,933		53,544
Accumulation Unit Value			$	8.556			$	9.445	$	31.146
Spinnaker Advisor
Net Assets			$	114,008			$	191,347	$	66,564
Accumulation Units Outstanding				13,336				20,275		2,500
Accumulation Unit Value			$	8.549			$	9.437	$	26.612
Spinnaker with EEB
Net Assets			$	-			$	-	$	-
Accumulation Units Outstanding				-				-		-
Accumulation Unit Value			$	-			$	-	$	-
Spinnaker with GMDB
Net Assets			$	-			$	-	$	-
Accumulation Units Outstanding				-				-		-
Accumulation Unit Value			$	-			$	-	$	-
Spinnaker with EEB & GMDB
Net Assets			$	-			$	-	$	-
Accumulation Units Outstanding				-				-		-
Accumulation Unit Value			$	-			$	-	$	-
Spinnaker Choice
Net Assets									$	-
Accumulation Units Outstanding										-
Accumulation Unit Value									$	-
Spinnaker Choice with EEB
Net Assets									$	-
Accumulation Units Outstanding										-
Accumulation Unit Value									$	-
Spinnaker Choice with GMDB
Net Assets									$	-
Accumulation Units Outstanding										-
Accumulation Unit Value									$	-
Spinnaker Choice with EEB & GMDB
Net Assets									$	-
Accumulation Units Outstanding										-
Accumulation Unit Value									$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
19

Symetra Separate Account C

Statements of Assets and Liabilities (continued)

As of December 31, 2009

	Sub-Accounts
	IBBOTSON GROWTH CLASS I		IBBOTSON GROWTH CLASS II	IBBOTSON INCOME AND GROWTH CLASS I		IBBOTSON INCOME AND GROWTH CLASS II	ING GLOBAL RESOURCES
Focus Tier I
Net Assets	$	241,608		$	25,419
Accumulation Units Outstanding		29,723			2,671
Accumulation Unit Value	$	8.129		$	9.517
Focus Tier II
Net Assets	$	17,421		$	187,808
Accumulation Units Outstanding		2,140			19,709
Accumulation Unit Value	$	8.139		$	9.529
Focus Tier III
Net Assets	$	55,693		$	-
Accumulation Units Outstanding		6,823			-
Accumulation Unit Value	$	8.160		$	-
Focus Tier IV
Net Assets	$	-		$	-
Accumulation Units Outstanding		-			-
Accumulation Unit Value	$	-		$	-
Focus Tier V
Net Assets	$	-		$	-
Accumulation Units Outstanding		-			-
Accumulation Unit Value	$	-		$	-
Focus Tier I with GMDB
Net Assets	$	-		$	7,323
Accumulation Units Outstanding		-			771
Accumulation Unit Value	$	-		$	9.492
Focus Tier II with GMDB
Net Assets	$	183,824		$	-
Accumulation Units Outstanding		22,642			-
Accumulation Unit Value	$	8.118		$	-
Focus Tier III with GMDB
Net Assets	$	-		$	-
Accumulation Units Outstanding		-			-
Accumulation Unit Value	$	-		$	-
Focus Tier IV with GMDB
Net Assets	$	-		$	-
Accumulation Units Outstanding		-			-
Accumulation Unit Value	$	-		$	-
Focus Tier V with GMDB
Net Assets	$	-		$	-
Accumulation Units Outstanding		-			-
Accumulation Unit Value	$	-		$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
20

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	ING JP MORGAN EMERGING MARKETS EQUITY I		JP MORGAN INSURANCE TRUST INTERNATIONAL EQUITY I1		JP MORGAN INSURANCE TRUST MID CAP VALUE I1		JP MORGAN INSURANCE TRUST U.S. EQUITY I1		MUTUAL SHARES SECURITIES
ASSETS:
Investments in Underlying
Investments, at Cost	$	1,170,901	$	9,282,754	$	6,024,002	$	3,334,810	$	9,494,010
Shares Owned		84,967		810,116		919,248		234,991		540,494
Investments, at Fair Value	$	1,731,630	$	7,728,524	$	5,120,208	$	3,273,423	$	7,880,369
Total Assets		1,731,630		7,728,524		5,120,208		3,273,423		7,880,369
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	1,731,630	$	7,728,524	$	5,120,208	$	3,273,423	$	7,880,369
Spinnaker & Mainsail
Net Assets	$	1,731,630	$	6,633,450	$	4,345,146	$	1,585,710	$	7,144,093
Accumulation Units Outstanding		77,533		392,727		286,908		205,475		614,281
Accumulation Unit Value	$	22.333	$	16.888	$	15.143	$	7.716	$	11.630
Spinnaker Advisor
Net Assets			$	1,055,446	$	725,842	$	1,687,713	$	664,268
Accumulation Units Outstanding				62,695		48,086		226,270		57,337
Accumulation Unit Value			$	16.832	$	15.092	$	7.458	$	11.585
Spinnaker with EEB
Net Assets			$	-	$	3,725			$	-
Accumulation Units Outstanding				-		249				-
Accumulation Unit Value			$	-	$	15.014			$	-
Spinnaker with GMDB
Net Assets			$	347	$	1,800			$	9,190
Accumulation Units Outstanding				22		122				802
Accumulation Unit Value			$	16.698	$	14.972			$	11.499
Spinnaker with EEB & GMDB
Net Assets			$	-	$	-			$	-
Accumulation Units Outstanding				-		-				-
Accumulation Unit Value			$	-	$	-			$	-
Spinnaker Choice
Net Assets			$	39,281	$	43,695			$	56,786
Accumulation Units Outstanding				3,129		3,727				5,235
Accumulation Unit Value			$	12.549	$	11.721			$	10.848
Spinnaker Choice with EEB
Net Assets			$	-	$	-			$	-
Accumulation Units Outstanding				-		-				-
Accumulation Unit Value			$	-	$	-			$	-
Spinnaker Choice with GMDB
Net Assets			$	-	$	-			$	6,032
Accumulation Units Outstanding				-		-				564
Accumulation Unit Value			$	-	$	-			$	10.726
Spinnaker Choice with EEB & GMDB
Net Assets			$	-	$	-			$	-
Accumulation Units Outstanding				-		-				-
Accumulation Unit Value			$	-	$	-			$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
21

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	NEUBERGER BERMAN AMT GUARDIAN CLASS S		NEUBERGER BERMAN AMT MID CAP GROWTH CLASS S		NEUBERGER BERMAN AMT REGENCY CLASS S		PIMCO ALL ASSET PORTFOLIO ADVISOR		PIMCO COMMODITY FUND ADMIN
ASSETS:
Investments in Underlying
Investments, at Cost	$	48,557	$	334,435	$	13,746	$	419,691	$	4,326,368
Shares Owned		3,010		18,497		1,255		42,762		417,918
Investments, at Fair Value	$	47,820	$	386,073	$	16,575	$	449,016	$	3,594,089
Total Assets		47,820		386,073		16,575		449,016		3,594,089
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	47,820	$	386,073	$	16,575	$	449,016	$	3,594,089
Spinnaker & Mainsail
Net Assets	$	47,606	$	351,142	$	16,575	$	413,365	$	2,939,992
Accumulation Units Outstanding		5,719		43,714		2,069		36,300		298,984
Accumulation Unit Value	$	8.324	$	8.033	$	8.013	$	11.387	$	9.833
Spinnaker Advisor
Net Assets	$	214	$	34,931	$	-	$	35,535	$	563,905
Accumulation Units Outstanding		28		4,353		-		3,128		57,481
Accumulation Unit Value	$	8.317	$	8.026	$	-	$	11.361	$	9.810
Spinnaker with EEB
Net Assets	$	-	$	-	$	-	$	-	$	2,103
Accumulation Units Outstanding		-		-		-		-		217
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	9.764
Spinnaker with GMDB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker with EEB & GMDB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker Choice
Net Assets							$	116	$	85,709
Accumulation Units Outstanding								11		8,781
Accumulation Unit Value							$	11.308	$	9.764
Spinnaker Choice with EEB
Net Assets							$	-	$	-
Accumulation Units Outstanding								-		-
Accumulation Unit Value							$	-	$	-
Spinnaker Choice with GMDB
Net Assets							$	-	$	2,380
Accumulation Units Outstanding								-		245
Accumulation Unit Value							$	-	$	9.673
Spinnaker Choice with EEB & GMDB
Net Assets							$	-	$	-
Accumulation Units Outstanding								-		-
Accumulation Unit Value							$	-	$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
22

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	PIONEER BOND VCT CLASS I		PIONEER EMERGING MARKETS VCT CLASS II		PIONEER EQUITY INCOME VCT CLASS II		PIONEER FUND VCT CLASS I		PIONEER GROWTH OPPORTUNITIES VCT CLASS I
ASSETS:
Investments in Underlying
Investments, at Cost	$	4,959,458	$	3,719,990	$	4,050,155	$	48,106,217	$	47,076,598
Shares Owned		457,717		139,666		220,293		2,109,947		2,127,129
Investments, at Fair Value	$	5,213,401	$	3,762,593	$	3,711,918	$	41,354,940	$	40,713,249
Total Assets		5,213,401		3,762,593		3,711,918		41,354,940		40,713,249
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	5,213,401	$	3,762,593	$	3,711,918	$	41,354,940	$	40,713,249
Spinnaker & Mainsail
Net Assets	$	4,139,523	$	2,979,178	$	3,365,682	$	40,995,646	$	39,610,528
Accumulation Units Outstanding		132,369		159,022		344,220		845,050		921,763
Accumulation Unit Value	$	31.294	$	18.734	$	9.778	$	48.511	$	42.971
Spinnaker Advisor
Net Assets	$	1,073,878	$	724,121	$	300,278	$	359,294	$	1,102,721
Accumulation Units Outstanding		70,178		38,750		30,789		47,186		109,326
Accumulation Unit Value	$	15.314	$	18.687	$	9.753	$	7.614	$	10.086
Spinnaker with EEB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker with GMDB
Net Assets	$	-	$	12,626	$	592	$	-	$	-
Accumulation Units Outstanding		-		682		65		-		-
Accumulation Unit Value	$	-	$	18.545	$	9.679	$	-	$	-
Spinnaker with EEB & GMDB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker Choice
Net Assets			$	46,668	$	45,366
Accumulation Units Outstanding				2,510		4,676
Accumulation Unit Value			$	18.592	$	9.703
Spinnaker Choice with EEB
Net Assets			$	-	$	-
Accumulation Units Outstanding				-		-
Accumulation Unit Value			$	-	$	-
Spinnaker Choice with GMDB
Net Assets			$	-	$	-
Accumulation Units Outstanding				-		-
Accumulation Unit Value			$	-	$	-
Spinnaker Choice with EEB & GMDB
Net Assets			$	-	$	-
Accumulation Units Outstanding				-		-
Accumulation Unit Value			$	-	$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
23

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	PIONEER HIGH YIELD VCT CLASS II		PIONEER MID-CAP VALUE VCT CLASS I		PIONEER MONEY MARKET VCT CLASS I		PIONEER REAL ESTATE VCT CLASS II		PIONEER STRATEGIC INCOME VCT CLASS II
ASSETS:
Investments in Underlying
Investments, at Cost	$	1,286,773	$	11,371,306	$	3,564,712	$	2,469,149	$	4,174,180
Shares Owned		158,386		610,358		3,564,712		210,292		418,305
Investments, at Fair Value	$	1,506,267	$	8,837,994	$	3,564,712	$	2,740,099	$	4,208,133
Total Assets		1,506,267		8,837,994		3,564,712		2,740,099		4,208,133
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	1,506,267	$	8,837,994	$	3,564,712	$	2,740,099	$	4,208,133
Spinnaker & Mainsail
Net Assets	$	1,180,820	$	8,557,915	$	2,904,163	$	2,156,337	$	3,441,768
Accumulation Units Outstanding		104,662		399,310		156,354		282,324		276,227
Accumulation Unit Value	$	11.292	$	21.431	$	18.581	$	7.638	$	12.460
Spinnaker Advisor
Net Assets	$	205,140	$	280,079	$	660,549	$	540,781	$	721,522
Accumulation Units Outstanding		18,223		32,975		60,188		70,934		58,058
Accumulation Unit Value	$	11.264	$	8.493	$	10.980	$	7.624	$	12.428
Spinnaker with EEB
Net Assets	$	-	$	-	$	-	$	2,007	$	-
Accumulation Units Outstanding		-		-		-		267		-
Accumulation Unit Value	$	-	$	-	$	-	$	7.596	$	-
Spinnaker with GMDB
Net Assets	$	-	$	-	$	-	$	555	$	-
Accumulation Units Outstanding		-		-		-		77		-
Accumulation Unit Value	$	-	$	-	$	-	$	7.582	$	-
Spinnaker with EEB & GMDB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker Choice
Net Assets	$	120,307					$	40,419	$	44,843
Accumulation Units Outstanding		10,755						5,322		3,633
Accumulation Unit Value	$	11.207					$	7.596	$	12.365
Spinnaker Choice with EEB
Net Assets	$	-					$	-	$	-
Accumulation Units Outstanding		-						-		-
Accumulation Unit Value	$	-					$	-	$	-
Spinnaker Choice with GMDB
Net Assets	$	-					$	-	$	-
Accumulation Units Outstanding		-						-		-
Accumulation Unit Value	$	-					$	-	$	-
Spinnaker Choice with EEB & GMDB
Net Assets	$	-					$	-	$	-
Accumulation Units Outstanding		-						-		-
Accumulation Unit Value	$	-					$	-	$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
24

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	SUMMIT BALANCE INDEX		SUMMIT BARCLAYS AGGREGATE BOND INDEX		SUMMIT EAFE INTERNATIONAL INDEX F CLASS		SUMMIT NASDAQ 100 INDEX		SUMMIT RUSSELL 2000 SMALL CAP INDEX F CLASS
ASSETS:
Investments in Underlying
Investments, at Cost	$	58,716	$	1,146,110	$	85,051	$	64,746	$	623,997
Shares Owned		1,415		22,062		1,165		3,380		15,638
Investments, at Fair Value	$	64,254	$	1,121,129	$	85,371	$	86,220	$	787,762
Total Assets		64,254		1,121,129		85,371		86,220		787,762
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	64,254	$	1,121,129	$	85,371	$	86,220	$	787,762
Spinnaker & Mainsail
Net Assets	$	64,254	$	970,011	$	23,478	$	78,617	$	645,726
Accumulation Units Outstanding		6,943		90,933		3,160		8,298		74,597
Accumulation Unit Value	$	9.255	$	10.667	$	7.419	$	9.474	$	8.656
Spinnaker Advisor
Net Assets	$	-	$	151,118	$	61,893	$	7,603	$	142,036
Accumulation Units Outstanding		-		14,176		8,361		802		16,421
Accumulation Unit Value	$	-	$	10.658	$	7.413	$	9.466	$	8.649
Spinnaker with EEB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker with GMDB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Spinnaker with EEB & GMDB
Net Assets	$	-			$	-	$	-	$	-
Accumulation Units Outstanding		-				-		-		-
Accumulation Unit Value	$	-			$	-	$	-	$	-
Spinnaker Choice
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker Choice with EEB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker Choice with GMDB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker Choice with EEB & GMDB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
25

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	SUMMIT S&P MID CAP 400 INDEX F CLASS		TEMPLETON DEVELOPING MARKETS II		TEMPLETON GLOBAL BOND SECURITIES II1		TEMPLETON GROWTH SECURITIES II		VANGUARD BALANCED
ASSETS:
Investments in Underlying
Investments, at Cost	$	60,469	$	6,112,403	$	5,943,608	$	7,374,019	$	817,013
Shares Owned		1,376		562,811		354,514		574,419		45,458
Investments, at Fair Value	$	75,818	$	5,504,297	$	6,143,719	$	5,973,934	$	788,683
Total Assets		75,818		5,504,297		6,143,719		5,973,934		788,683
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	75,818	$	5,504,297	$	6,143,719	$	5,973,934	$	788,683
Spinnaker & Mainsail
Net Assets	$	75,818	$	4,758,030	$	5,216,618	$	5,574,153
Accumulation Units Outstanding		8,833		223,664		356,507		491,961
Accumulation Unit Value	$	8.582	$	21.274	$	14.633	$	11.333
Spinnaker Advisor
Net Assets	$	-	$	720,107	$	839,397	$	355,816
Accumulation Units Outstanding		-		32,728		57,500		31,517
Accumulation Unit Value	$	-	$	22.003	$	14.598	$	11.290
Spinnaker with EEB
Net Assets	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-
Spinnaker with GMDB
Net Assets	$	-	$	-	$	-	$	7,384
Accumulation Units Outstanding		-		-		-		659
Accumulation Unit Value	$	-	$	-	$	-	$	11.205
Spinnaker with EEB & GMDB
Net Assets	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-
Spinnaker Choice
Net Assets			$	23,712	$	83,609	$	30,704
Accumulation Units Outstanding				1,229		5,756		2,882
Accumulation Unit Value			$	19.297	$	14.530	$	10.657
Spinnaker Choice with EEB
Net Assets			$	-	$	-	$	-
Accumulation Units Outstanding				-		-		-
Accumulation Unit Value			$	-	$	-	$	-
Spinnaker Choice with GMDB
Net Assets			$	2,448	$	4,095	$	5,877
Accumulation Units Outstanding				128		285		558
Accumulation Unit Value			$	19.080	$	14.395	$	10.537
Spinnaker Choice with EEB & GMDB
Net Assets			$	-	$	-	$	-
Accumulation Units Outstanding				-		-		-
Accumulation Unit Value			$	-	$	-	$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
26

Symetra Separate Account C

Statements of Assets and Liabilities (continued)

As of December 31, 2009

	Sub-Accounts
	SUMMIT S&P MID CAP 400 INDEX F CLASS	TEMPLETON DEVELOPING MARKETS II	TEMPLETON GLOBAL BOND SECURITIES II1	TEMPLETON GROWTH SECURITIES II	VANGUARD BALANCED
Focus Tier I
Net Assets					$	250,185
Accumulation Units Outstanding						26,972
Accumulation Unit Value					$	9.276
Focus Tier II
Net Assets					$	27,917
Accumulation Units Outstanding						3,006
Accumulation Unit Value					$	9.288
Focus Tier III
Net Assets					$	76,492
Accumulation Units Outstanding						8,215
Accumulation Unit Value					$	9.312
Focus Tier IV
Net Assets					$	-
Accumulation Units Outstanding						-
Accumulation Unit Value					$	-
Focus Tier V
Net Assets					$	-
Accumulation Units Outstanding						-
Accumulation Unit Value					$	-
Focus Tier I with GMDB
Net Assets					$	3,009
Accumulation Units Outstanding						327
Accumulation Unit Value					$	9.252
Focus Tier II with GMDB
Net Assets					$	353,038
Accumulation Units Outstanding						38,110
Accumulation Unit Value					$	9.264
Focus Tier III with GMDB
Net Assets					$	-
Accumulation Units Outstanding						-
Accumulation Unit Value					$	-
Focus Tier IV with GMDB
Net Assets					$	-
Accumulation Units Outstanding						-
Accumulation Unit Value					$	-
Focus Tier V with GMDB
Net Assets					$	78,042
Accumulation Units Outstanding						8,360
Accumulation Unit Value					$	9.336

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
27

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	VANGUARD HIGH YIELD BOND		VANGUARD INTERNATIONAL		VANGUARD MID-CAP INDEX		VANGUARD REIT INDEX		VANGUARD TOTAL BOND MARKET INDEX
ASSETS:
Investments in Underlying
Investments, at Cost	$	775,719	$	1,131,715	$	1,527,998	$	404,969	$	3,846,300
Shares Owned		112,170		78,119		139,651		53,398		337,282
Investments, at Fair Value	$	836,784	$	1,254,612	$	1,678,612	$	443,210	$	3,969,815
Total Assets		836,784		1,254,612		1,678,612		443,210		3,969,815
LIABILITIES:
Total Liabilities		-		-		-		-		-
NET ASSETS	$	836,784	$	1,254,612	$	1,678,612	$	443,210	$	3,969,815
Spinnaker & Mainsail
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker Advisor
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker with EEB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker with GMDB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker with EEB & GMDB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker Choice
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker Choice with EEB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker Choice with GMDB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker Choice with EEB & GMDB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
28

Symetra Separate Account C

Statements of Assets and Liabilities (continued)

As of December 31, 2009

	Sub-Accounts
	VANGUARD HIGH YIELD BOND		VANGUARD INTERNATIONAL		VANGUARD MID-CAP INDEX		VANGUARD REIT INDEX		VANGUARD TOTAL BOND MARKET INDEX
Focus Tier I
Net Assets	$	238,062	$	360,285	$	567,792	$	147,456	$	733,116
Accumulation Units Outstanding		23,216		45,640		77,366		23,412		64,371
Accumulation Unit Value	$	10.255	$	7.894	$	7.339	$	6.299	$	11.389
Focus Tier II
Net Assets	$	216,127	$	417,419	$	591,867	$	182,595	$	1,074,000
Accumulation Units Outstanding		21,049		52,809		80,542		28,953		94,180
Accumulation Unit Value	$	10.268	$	7.904	$	7.349	$	6.307	$	11.404
Focus Tier III
Net Assets	$	146,791	$	214,012	$	345,172	$	72,770	$	551,001
Accumulation Units Outstanding		14,260		27,006		46,850		11,509		48,193
Accumulation Unit Value	$	10.294	$	7.925	$	7.368	$	6.323	$	11.433
Focus Tier IV
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Focus Tier V
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Focus Tier I with GMDB
Net Assets	$	51,467	$	52,170	$	129,012	$	15,361	$	214,301
Accumulation Units Outstanding		5,032		6,626		17,624		2,444		18,865
Accumulation Unit Value	$	10.228	$	7.874	$	7.320	$	6.282	$	11.360
Focus Tier II with GMDB
Net Assets	$	29,339	$	50,184	$	44,769	$	25,028	$	294,369
Accumulation Units Outstanding		2,865		6,365		6,107		3,979		25,879
Accumulation Unit Value	$	10.241	$	7.884	$	7.330	$	6.290	$	11.374
Focus Tier III with GMDB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Focus Tier IV with GMDB
Net Assets	$	-	$	-	$	-	$	-	$	-
Accumulation Units Outstanding		-		-		-		-		-
Accumulation Unit Value	$	-	$	-	$	-	$	-	$	-
Focus Tier V with GMDB
Net Assets	$	154,998	$	160,542	$	-	$	-	$	1,103,028
Accumulation Units Outstanding		15,018		20,206		-		-		96,229
Accumulation Unit Value	$	10.321	$	7.945	$	-	$	-	$	11.463

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
29

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2009

	Sub-Accounts
	VANGUARD TOTAL STOCK MARKET INDEX		WANGER USA
ASSETS:
Investments in Underlying
Investments, at Cost	$	2,394,368	$	292,898
Shares Owned		119,063		11,846
Investments, at Fair Value	$	2,587,251	$	325,191
Total Assets		2,587,251		325,191
LIABILITIES:
Total Liabilities		-		-
NET ASSETS	$	2,587,251	$	325,191
Spinnaker & Mainsail
Net Assets			$	325,191
Accumulation Units Outstanding				8,453
Accumulation Unit Value			$	38.470
Spinnaker Advisor
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker with EEB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker with GMDB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker with EEB & GMDB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker Choice
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker Choice with EEB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker Choice with GMDB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value
Spinnaker Choice with EEB & GMDB
Net Assets
Accumulation Units Outstanding
Accumulation Unit Value

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
30

Symetra Separate Account C

Statements of Assets and Liabilities (continued)

As of December 31, 2009

	Sub-Accounts
	VANGUARD TOTAL STOCK MARKET INDEX		WANGER USA
Focus Tier I
Net Assets	$	742,620
Accumulation Units Outstanding		99,987
Accumulation Unit Value	$	7.427
Focus Tier II
Net Assets	$	1,049,429
Accumulation Units Outstanding		141,114
Accumulation Unit Value	$	7.437
Focus Tier III
Net Assets	$	456,727
Accumulation Units Outstanding		61,256
Accumulation Unit Value	$	7.456
Focus Tier IV
Net Assets	$	-
Accumulation Units Outstanding		-
Accumulation Unit Value	$	-
Focus Tier V
Net Assets	$	-
Accumulation Units Outstanding		-
Accumulation Unit Value	$	-
Focus Tier I with GMDB
Net Assets	$	182,888
Accumulation Units Outstanding		24,688
Accumulation Unit Value	$	7.408
Focus Tier II with GMDB
Net Assets	$	155,587
Accumulation Units Outstanding		20,976
Accumulation Unit Value	$	7.418
Focus Tier III with GMDB
Net Assets	$	-
Accumulation Units Outstanding		-
Accumulation Unit Value	$	-
Focus Tier IV with GMDB
Net Assets	$	-
Accumulation Units Outstanding		-
Accumulation Unit Value	$	-
Focus Tier V with GMDB
Net Assets	$	-
Accumulation Units Outstanding		-
Accumulation Unit Value	$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
31

Symetra Separate Account C

Statements of Operations

Year Ended December 31, 2009

	Sub-Accounts
	AIM CAPITAL APPRECIATION I			AIM CAPITAL APPRECIATION II			AIM CAPITAL DEVELOPMENT SERIES I			AIM CAPITAL DEVELOPMENT SERIES II			AIM GLOBAL HEALTHCARE
Investment Income
Dividend Income	$	29,166		$	2,194		$	-		$	-		$	1,702
Mortality and Expense Risk Charge		(57,354	)		(9,618	)		(2,868	)		(6,335	)		(6,155	)
Asset-Related Administration Charge		(6,974	)		(1,171	)		(362	)		(776	)		(786	)
Net Investment Income (Loss)		(35,162	)		(8,595	)		(3,230	)		(7,111	)		(5,239	)
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		(458,510	)		(154,807	)		(41,411	)		(147,680	)		(45,575	)
Realized Capital Gain Distributions Received		-			-			-			-			-
Net Change in Unrealized Appreciation (Depreciation)		1,328,045			304,174			121,275			327,912			162,701
Net Gain (Loss) on Investments		869,535			149,367			79,864			180,232			117,126
Net Increase (Decrease) in Net Assets Resulting from Operations	$	834,373		$	140,772		$	76,634		$	173,121		$	111,887
	Sub-Accounts
	AIM GLOBAL REAL ESTATE			AIM INTERNATIONAL GROWTH I			AIM INTERNATIONAL GROWTH II			AIM SMALL CAP EQUITY II			AMERICAN CENTURY BALANCED
Investment Income
Dividend Income	$	-		$	28,896		$	100,123		$	87		$	573,427
Mortality and Expense Risk Charge		(83,496	)		(23,244	)		(80,901	)		(618	)		(135,512	)
Asset-Related Administration Charge		(10,600	)		(2,885	)		(10,030	)		(82	)		(17,311	)
Net Investment Income (Loss)		(94,096	)		2,767			9,192			(613	)		420,604
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		(1,604,818	)		(7,925	)		(786,742	)		(5,699	)		(925,032	)
Realized Capital Gain Distributions Received		-			-			-			-			-
Net Change in Unrealized Appreciation (Depreciation)		3,502,775			549,246			2,731,455			20,222			1,883,337
Net Gain (Loss) on Investments		1,897,957			541,321			1,944,713			14,523			958,305
Net Increase (Decrease) in Net Assets Resulting from Operations	$	1,803,861		$	544,088		$	1,953,905		$	13,910		$	1,378,909

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
32

Symetra Separate Account C

Statements of Operations

Year Ended December 31, 2009

	Sub-Accounts
	AMERICAN CENTURY INFLATION PROTECTION II			AMERICAN CENTURY INTERNATIONAL			AMERICAN CENTURY LARGE COMPANY VALUE II			AMERICAN CENTURY ULTRA I			AMERICAN CENTURY ULTRA II
Investment Income
Dividend Income	$	75,672		$	203,633		$	21,261		$	982		$	145
Mortality and Expense Risk Charge		(52,686	)		(123,605	)		(5,379	)		(4,337	)		(1,074	)
Asset-Related Administration Charge		(6,852	)		(15,298	)		(705	)		(545	)		(131	)
Net Investment Income (Loss)		16,134			64,730			15,177			(3,900	)		(1,060	)
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		14,548			(736,543	)		(118,338	)		(34,307	)		(19,445	)
Realized Capital Gain Distributions Received		-			-			-			-			-
Net Change in Unrealized Appreciation (Depreciation)		320,746			3,475,463			180,754			139,721			45,488
Net Gain (Loss) on Investments		335,294			2,738,920			62,416			105,414			26,043
Net Increase (Decrease) in Net Assets Resulting from Operations	$	351,428		$	2,803,650		$	77,593		$	101,514		$	24,983
	Sub-Accounts
	AMERICAN CENTURY VALUE			DREYFUS APPRECIATION			DREYFUS MIDCAP STOCK			DREYFUS QUALITY BOND			DREYFUS SOCIALLY RESPONSIBLE
Investment Income
Dividend Income	$	178,022		$	106,564		$	152,263		$	253,965		$	27,613
Mortality and Expense Risk Charge		(40,563	)		(50,894	)		(132,794	)		(66,581	)		(36,121	)
Asset-Related Administration Charge		(4,991	)		(6,544	)		(17,075	)		(8,607	)		(4,506	)
Net Investment Income (Loss)		132,468			49,126			2,394			178,777			(13,014	)
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		(503,852	)		(176,614	)		(2,492,383	)		(197,326	)		(211,828	)
Realized Capital Gain Distributions Received		-			310,953			-			-			-
Net Change in Unrealized Appreciation (Depreciation)		974,975			602,510			5,612,663			669,020			1,049,548
Net Gain (Loss) on Investments		471,123			736,849			3,120,280			471,694			837,720
Net Increase (Decrease) in Net Assets Resulting from Operations	$	603,591		$	785,975		$	3,122,674		$	650,471		$	824,706

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
33

Symetra Separate Account C

Statements of Operations

Year Ended December 31, 2009

	Sub-Accounts
	DREYFUS STOCK INDEX			DREYFUS TECHNOLOGY GROWTH			DWS BALANCED VIP A			DWS CAPITAL GROWTH VIP B			DWS GLOBAL OPPORTUNITIES B SHARE
Investment Income
Dividend Income	$	224,921		$	11,104		$	455,117		$	7,329		$	72
Mortality and Expense Risk Charge		(152,622	)		(31,504	)		(147,960	)		(12,113	)		(196	)
Asset-Related Administration Charge		(19,859	)		(4,046	)		(18,356	)		(1,496	)		(25	)
Net Investment Income (Loss)		52,440			(24,446	)		288,801			(6,280	)		(149	)
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		(1,490,348	)		(202,824	)		(890,045	)		(50,167	)		(15	)
Realized Capital Gain Distributions Received		739,969			-			-			-			-
Net Change in Unrealized Appreciation (Depreciation)		3,469,157			1,349,935			2,914,037			333,849			2,961
Net Gain (Loss) on Investments		2,718,778			1,147,111			2,023,992			283,682			2,946
Net Increase (Decrease) in Net Assets Resulting from Operations	$	2,771,218		$	1,122,665		$	2,312,793		$	277,402		$	2,797
	Sub-Accounts
	DWS GLOBAL THEMATIC B SHARE			DWS INTERNATIONAL VIP A			DWS SMALL CAP INDEX A SHARE			FEDERATED CAPITAL INCOME			FEDERATED HIGH INCOME BOND
Investment Income
Dividend Income	$	60		$	181,412		$	372		$	101,116		$	342,044
Mortality and Expense Risk Charge		(150	)		(51,456	)		(350	)		(20,032	)		(37,274	)
Asset-Related Administration Charge		(18	)		(6,209	)		(130	)		(2,422	)		(4,714	)
Net Investment Income (Loss)		(108	)		123,747			(108	)		78,662			300,056
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		69			(664,302	)		(303	)		(189,675	)		(299,970	)
Realized Capital Gain Distributions Received		-			-			1,395			-			-
Net Change in Unrealized Appreciation (Depreciation)		4,586			1,682,268			9,186			486,290			1,207,413
Net Gain (Loss) on Investments		4,655			1,017,966			10,278			296,615			907,443
Net Increase (Decrease) in Net Assets Resulting from Operations	$	4,547		$	1,141,713		$	10,170		$	375,277		$	1,207,499

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
34

Symetra Separate Account C

Statements of Operations

Year Ended December 31, 2009

	Sub-Accounts
	FEDERATED INTERNATIONAL EQUITY			FIDELITY ASSET MANAGER			FIDELITY CONTRAFUND			FIDELITY EQUITY INCOME			FIDELITY FREEDOM FUNDS 2010 II
Investment Income
Dividend Income	$	27,457		$	10,221		$	350,555		$	163,814		$	3,413
Mortality and Expense Risk Charge		(11,622	)		(5,207	)		(302,587	)		(87,109	)		(1,009	)
Asset-Related Administration Charge		(1,395	)		(679	)		(37,097	)		(10,851	)		(140	)
Net Investment Income (Loss)		14,440			4,335			10,871			65,854			2,264
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		(145,103	)		(22,982	)		(2,285,831	)		(1,359,517	)		(325	)
Realized Capital Gain Distributions Received		-			718			7,016			-			614
Net Change in Unrealized Appreciation (Depreciation)		448,234			119,121			9,645,687			3,114,631			15,203
Net Gain (Loss) on Investments		303,131			96,857			7,366,872			1,755,114			15,492
Net Increase (Decrease) in Net Assets Resulting from Operations	$	317,571		$	101,192		$	7,377,743		$	1,820,968		$	17,756
	Sub-Accounts
	FIDELITY FREEDOM FUNDS 2015 II			FIDELITY FREEDOM FUNDS 2020 II			FIDELITY FREEDOM FUNDS 2025 II			FIDELITY FREEDOM FUNDS 2030 II			FIDELITY FREEDOM INCOME FUND II
Investment Income
Dividend Income	$	2,065		$	14,917		$	6,859		$	2,426		$	1,655
Mortality and Expense Risk Charge		(565	)		(5,597	)		(2,047	)		(867	)		(592	)
Asset-Related Administration Charge		(74	)		(675	)		(294	)		(117	)		(72	)
Net Investment Income (Loss)		1,426			8,645			4,518			1,442			991
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		(1,636	)		(5,316	)		1,131			(36,831	)		(665	)
Realized Capital Gain Distributions Received		622			5,620			1,972			218			743
Net Change in Unrealized Appreciation (Depreciation)		10,258			101,463			45,845			53,990			4,594
Net Gain (Loss) on Investments		9,244			101,767			48,948			17,377			4,672
Net Increase (Decrease) in Net Assets Resulting from Operations	$	10,670		$	110,412		$	53,466		$	18,819		$	5,663

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
35

Symetra Separate Account C

Statements of Operations

Year Ended December 31, 2009

	Sub-Accounts
	FIDELITY GROWTH			FIDELITY GROWTH & INCOME			FIDELITY GROWTH OPPORTUNITIES			FIDELITY INDEX 500			FIDELITY MID-CAP ADVISOR II
Investment Income
Dividend Income	$	49,348		$	67,195		$	12,457		$	7,338		$	30,622
Mortality and Expense Risk Charge		(137,027	)		(76,811	)		(32,857	)		(2,661	)		(80,713	)
Asset-Related Administration Charge		(17,147	)		(9,805	)		(4,008	)		(1,003	)		(10,258	)
Net Investment Income (Loss)		(104,826	)		(19,421	)		(24,408	)		3,674			(60,349	)
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		(1,089,082	)		(658,416	)		(268,988	)		(56,459	)		(899,797	)
Realized Capital Gain Distributions Received		9,707			-			-			5,203			35,741
Net Change in Unrealized Appreciation (Depreciation)		3,786,648			2,084,941			1,270,439			113,330			3,028,875
Net Gain (Loss) on Investments		2,707,273			1,426,525			1,001,451			62,074			2,164,819
Net Increase (Decrease) in Net Assets Resulting from Operations	$	2,602,447		$	1,407,104		$	977,043		$	65,748		$	2,104,470
	Sub-Accounts
	FIDELITY MONEY MARKET FUND			FIDELITY OVERSEAS II			FIDELITY VIP MONEY MARKET SERVICE CLASS			FRANKLIN FLEX CAP GROWTH SECURITIES			FRANKLIN FOUNDING ALLOCATION FUND CLASS II
Investment Income
Dividend Income	$	7,826		$	2,207		$	61,643		$	-		$	7,955
Mortality and Expense Risk Charge		(10,191	)		(757	)		(168,597	)		(2,582	)		(2,910	)
Asset-Related Administration Charge		(3,598	)		(102	)		(22,261	)		(322	)		(368	)
Net Investment Income (Loss)		(5,963	)		1,348			(129,215	)		(2,904	)		4,677
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		-			423			-			(13,406	)		(15,858	)
Realized Capital Gain Distributions Received		-			271			-			-			-
Net Change in Unrealized Appreciation (Depreciation)		-			12,459			-			79,461			76,861
Net Gain (Loss) on Investments		-			13,153			-			66,055			61,003
Net Increase (Decrease) in Net Assets Resulting from Operations	$	(5,963	)	$	14,501		$	(129,215	)	$	63,151		$	65,680

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
36

Symetra Separate Account C

Statements of Operations

Year Ended December 31, 2009

	Sub-Accounts
	FRANKLIN INCOME SECURITIES FUND CLASS II			FRANKLIN SMALL CAP VALUE FUND II			FRANKLIN SMALL-MID CAP GROWTH II			FRANKLIN U.S. GOVERNMENT II			IBBOTSON AGGRESSIVE GROWTH CLASS I
Investment Income
Dividend Income	$	475,285		$	87,360		$	-		$	630,680		$	1,493
Mortality and Expense Risk Charge		(69,904	)		(61,671	)		(51,053	)		(213,680	)		(2,361	)
Asset-Related Administration Charge		(8,875	)		(7,806	)		(6,333	)		(28,227	)		(955	)
Net Investment Income (Loss)		396,506			17,883			(57,386	)		388,773			(1,823	)
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		(631,054	)		(1,084,463	)		(342,541	)		266,729			(28,762	)
Realized Capital Gain Distributions Received		-			240,581			-			-			99
Net Change in Unrealized Appreciation (Depreciation)		1,901,545			2,256,380			1,853,177			(380,453	)		93,605
Net Gain (Loss) on Investments		1,270,491			1,412,498			1,510,636			(113,724	)		64,942
Net Increase (Decrease) in Net Assets Resulting from Operations	$	1,666,997		$	1,430,381		$	1,453,250		$	275,049		$	63,119
	Sub-Accounts
	IBBOTSON AGGRESSIVE GROWTH CLASS II			IBBOTSON BALANCED CLASS I			IBBOTSON BALANCED CLASS II			IBBOTSON CONSERVATIVE CLASS I			IBBOTSON CONSERVATIVE CLASS II
Investment Income
Dividend Income	$	13,404		$	9,628		$	23,544		$	950		$	3,353
Mortality and Expense Risk Charge		(17,200	)		(9,487	)		(23,720	)		(1,519	)		(4,974	)
Asset-Related Administration Charge		(2,065	)		(3,365	)		(2,943	)		(586	)		(723	)
Net Investment Income (Loss)		(5,861	)		(3,224	)		(3,119	)		(1,155	)		(2,344	)
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		(18,892	)		(116,020	)		(2,018	)		(227	)		1,821
Realized Capital Gain Distributions Received		523			805			2,323			102			346
Net Change in Unrealized Appreciation (Depreciation)		402,869			284,752			477,955			12,029			41,301
Net Gain (Loss) on Investments		384,500			169,537			478,260			11,904			43,468
Net Increase (Decrease) in Net Assets Resulting from Operations	$	378,639		$	166,313		$	475,141		$	10,749		$	41,124

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
37

Symetra Separate Account C

Statements of Operations

Year Ended December 31, 2009

	Sub-Accounts
	IBBOTSON GROWTH CLASS I			IBBOTSON GROWTH CLASS II			IBBOTSON INCOME AND GROWTH CLASS I			IBBOTSON INCOME AND GROWTH CLASS II			ING GLOBAL RESOURCES
Investment Income
Dividend Income	$	3,183		$	10,884		$	2,261		$	6,093		$	4,626
Mortality and Expense Risk Charge		(4,077	)		(11,223	)		(1,916	)		(6,182	)		(18,747	)
Asset-Related Administration Charge		(1,551	)		(1,387	)		(718	)		(770	)		(2,283	)
Net Investment Income (Loss)		(2,445	)		(1,726	)		(373	)		(859	)		(16,404	)
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		(120,224	)		4,472			(2,727	)		7,390			(55,089	)
Realized Capital Gain Distributions Received		149			516			132			540			-
Net Change in Unrealized Appreciation (Depreciation)		155,838			255,379			26,752			61,619			531,586
Net Gain (Loss) on Investments		35,763			260,367			24,157			69,549			476,497
Net Increase (Decrease) in Net Assets Resulting from Operations	$	33,318		$	258,641		$	23,784		$	68,690		$	460,093
	Sub-Accounts
	ING JP MORGAN EMERGING MARKETS EQUITY I			JP MORGAN INSURANCE TRUST INTERNATIONAL EQUITY I1			JP MORGAN INSURANCE TRUST MID CAP VALUE I1			JP MORGAN INSURANCE TRUST U.S. EQUITY I1			JP MORGAN INTERNATIONAL EQUITY1
Investment Income
Dividend Income	$	23,033		$	110,894		$	-		$	-		$	283,516
Mortality and Expense Risk Charge		(18,012	)		(60,872	)		(40,509	)		(25,680	)		(21,441	)
Asset-Related Administration Charge		(2,161	)		(7,628	)		(5,110	)		(3,607	)		(2,688	)
Net Investment Income (Loss)		2,860			42,394			(45,619	)		(29,287	)		259,387
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		62,222			(462,467	)		(340,903	)		(54,387	)		(378,428	)
Realized Capital Gain Distributions Received		-			-			-			-			277,120
Net Change in Unrealized Appreciation (Depreciation)		686,935			(1,554,233	)		(903,791	)		(61,387	)		3,767,344
Net Gain (Loss) on Investments		749,157			(2,016,700	)		(1,244,694	)		(115,774	)		3,666,036
Net Increase (Decrease) in Net Assets Resulting from Operations	$	752,017		$	(1,974,306	)	$	(1,290,313	)	$	(145,061	)	$	3,925,423

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
38

Symetra Separate Account C

Statements of Operations

Year Ended December 31, 2009

	Sub-Accounts
	JP MORGAN MID-CAP VALUE1			JP MORGAN US LARGE CAP CORE EQUITY1			MUTUAL SHARES SECURITIES			NEUBERGER BERMAN AMT GUARDIAN CLASS S			NEUBERGER BERMAN AMT MID CAP GROWTH CLASS S
Investment Income
Dividend Income	$	105,568		$	65,279		$	129,975		$	394		$	-
Mortality and Expense Risk Charge		(15,979	)		(9,711	)		(83,264	)		(470	)		(3,333	)
Asset-Related Administration Charge		(2,023	)		(1,362	)		(10,274	)		(56	)		(410	)
Net Investment Income (Loss)		87,566			54,206			36,437			(132	)		(3,743	)
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		(319,477	)		(61,001	)		(553,024	)		(5,639	)		(18,288	)
Realized Capital Gain Distributions Received		9,556			-			-			-			-
Net Change in Unrealized Appreciation (Depreciation)		2,529,366			935,542			2,021,872			15,237			104,652
Net Gain (Loss) on Investments		2,219,445			874,541			1,468,848			9,598			86,364
Net Increase (Decrease) in Net Assets Resulting from Operations	$	2,307,011		$	928,747		$	1,505,285		$	9,466		$	82,621
	Sub-Accounts
	NEUBERGER BERMAN AMT REGENCY CLASS S			PIMCO ALL ASSET PORTFOLIO ADVISOR			PIMCO COMMODITY FUND ADMIN			PIONEER BOND VCT CLASS I			PIONEER EMERGING MARKETS VCT CLASS II
Investment Income
Dividend Income	$	88		$	29,231		$	174,247		$	286,322		$	24,985
Mortality and Expense Risk Charge		(75	)		(5,216	)		(35,380	)		(64,155	)		(35,364	)
Asset-Related Administration Charge		(9	)		(641	)		(4,446	)		(8,233	)		(4,508	)
Net Investment Income (Loss)		4			23,374			134,421			213,934			(14,887	)
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		27			(17,074	)		(414,290	)		(70,813	)		(751,329	)
Realized Capital Gain Distributions Received		128			-			288,321			-			-
Net Change in Unrealized Appreciation (Depreciation)		2,830			87,220			962,330			612,985			2,263,867
Net Gain (Loss) on Investments		2,985			70,146			836,361			542,172			1,512,538
Net Increase (Decrease) in Net Assets Resulting from Operations	$	2,989		$	93,520		$	970,782		$	756,106		$	1,497,651

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
39

Symetra Separate Account C

Statements of Operations

Year Ended December 31, 2009

	Sub-Accounts
	PIONEER EQUITY INCOME VCT CLASS II			PIONEER FUND VCT CLASS I			PIONEER GROWTH OPPORTUNITIES VCT CLASS I			PIONEER HIGH YIELD VCT CLASS II			PIONEER MID-CAP VALUE VCT CLASS I
Investment Income
Dividend Income	$	93,580		$	671,129		$	-		$	114,775		$	124,689
Mortality and Expense Risk Charge		(37,537	)		(464,119	)		(436,683	)		(19,193	)		(100,314	)
Asset-Related Administration Charge		(4,614	)		(55,862	)		(52,893	)		(2,293	)		(12,166	)
Net Investment Income (Loss)		51,429			151,148			(489,576	)		93,289			12,209
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		(584,135	)		(2,909,025	)		(2,156,347	)		(110,298	)		(1,208,806	)
Realized Capital Gain Distributions Received		-			-			-			-			-
Net Change in Unrealized Appreciation (Depreciation)		995,539			10,722,600			15,256,684			667,344			2,927,078
Net Gain (Loss) on Investments		411,404			7,813,575			13,100,337			557,046			1,718,272
Net Increase (Decrease) in Net Assets Resulting from Operations	$	462,833		$	7,964,723		$	12,610,761		$	650,335		$	1,730,481
	Sub-Accounts
	PIONEER MONEY MARKET VCT CLASS I			PIONEER REAL ESTATE VCT CLASS II			PIONEER SMALL-CAP VALUE VCT CLASS I1			PIONEER SMALL-CAP VALUE VCT CLASS II1			PIONEER STRATEGIC INCOME VCT CLASS II
Investment Income
Dividend Income	$	6,433		$	95,624		$	59,063		$	10,840		$	233,030
Mortality and Expense Risk Charge		(45,995	)		(26,371	)		(21,494	)		(6,481	)		(36,881	)
Asset-Related Administration Charge		(5,862	)		(3,364	)		(2,713	)		(814	)		(4,704	)
Net Investment Income (Loss)		(45,424	)		65,889			34,856			3,545			191,445
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		-			(1,113,017	)		(8,409,384	)		(1,973,509	)		(128,719	)
Realized Capital Gain Distributions Received		-			-			-			-			146,085
Net Change in Unrealized Appreciation (Depreciation)		-			1,835,835			7,976,090			1,860,084			479,134
Net Gain (Loss) on Investments		-			722,818			(433,294	)		(113,425	)		496,500
Net Increase (Decrease) in Net Assets Resulting from Operations	$	(45,424	)	$	788,707		$	(398,438	)	$	(109,880	)	$	687,945

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
40

Symetra Separate Account C

Statements of Operations

Year Ended December 31, 2009

	Sub-Accounts
	SUMMIT BALANCE INDEX			SUMMIT BARCLAYS AGGREGATE BOND INDEX			SUMMIT EAFE INTERNATIONAL INDEX F CLASS			SUMMIT NASDAQ 100 INDEX			SUMMIT RUSSELL 2000 SMALL CAP INDEX F CLASS
Investment Income
Dividend Income	$	1,407		$	52,203		$	727		$	64		$	2,067
Mortality and Expense Risk Charge		(592	)		(8,060	)		(324	)		(666	)		(6,584	)
Asset-Related Administration Charge		(71	)		(1,006	)		(45	)		(83	)		(836	)
Net Investment Income (Loss)		744			43,137			358			(685	)		(5,353	)
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		5,317			5,917			2,892			736			(36,509	)
Realized Capital Gain Distributions Received		-			4,224			-			-			8,503
Net Change in Unrealized Appreciation (Depreciation)		5,882			(33,447	)		341			22,803			215,921
Net Gain (Loss) on Investments		11,199			(23,306	)		3,233			23,539			187,915
Net Increase (Decrease) in Net Assets Resulting from Operations	$	11,943		$	19,831		$	3,591		$	22,854		$	182,562
	Sub-Accounts
	SUMMIT S&P MID CAP 400 INDEX F CLASS			TEMPLETON DEVELOPING MARKETS II			TEMPLETON GLOBAL BOND SECURITIES II1			TEMPLETON GROWTH SECURITIES II			VANGUARD BALANCED
Investment Income
Dividend Income	$	323		$	171,479		$	636,407		$	155,873		$	25,763
Mortality and Expense Risk Charge		(1,399	)		(53,097	)		(57,844	)		(61,368	)		(6,299	)
Asset-Related Administration Charge		(168	)		(6,636	)		(7,194	)		(7,532	)		(2,182	)
Net Investment Income (Loss)		(1,244	)		111,746			571,369			86,973			17,282
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		31,861			(603,388	)		21,127			(269,322	)		(9,136	)
Realized Capital Gain Distributions Received		-			16,557			-			-			-
Net Change in Unrealized Appreciation (Depreciation)		20,295			2,759,140			128,745			1,523,360			119,747
Net Gain (Loss) on Investments		52,156			2,172,309			149,872			1,254,038			110,611
Net Increase (Decrease) in Net Assets Resulting from Operations	$	50,912		$	2,284,055		$	721,241		$	1,341,011		$	127,893

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
41

Symetra Separate Account C

Statements of Operations

Year Ended December 31, 2009

	Sub-Accounts
	VANGUARD HIGH YIELD BOND			VANGUARD INTERNATIONAL			VANGUARD MID-CAP INDEX			VANGUARD REIT INDEX			VANGUARD TOTAL BOND MARKET INDEX
Investment Income
Dividend Income	$	53,030		$	30,251		$	24,455		$	17,290		$	125,452
Mortality and Expense Risk Charge		(6,717	)		(8,606	)		(13,892	)		(3,384	)		(31,687	)
Asset-Related Administration Charge		(1,981	)		(2,891	)		(4,493	)		(1,126	)		(8,876	)
Net Investment Income (Loss)		44,332			18,754			6,070			12,780			84,889
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		(31,527	)		(69,624	)		(318,794	)		(126,736	)		6,227
Realized Capital Gain Distributions Received		-			-			61,140			23,084			-
Net Change in Unrealized Appreciation (Depreciation)		198,442			380,138			754,430			202,151			42,355
Net Gain (Loss) on Investments		166,915			310,514			496,776			98,499			48,582
Net Increase (Decrease) in Net Assets Resulting from Operations	$	211,247		$	329,268		$	502,846		$	111,279		$	133,471

	Sub-Accounts
	VANGUARD TOTAL STOCK MARKET INDEX			WANGER USA
Investment Income
Dividend Income	$	42,477		$	-
Mortality and Expense Risk Charge		(21,356	)		(3,725	)
Asset-Related Administration Charge		(7,039	)		(447	)
Net Investment Income (Loss)		14,082			(4,172	)
Realized and Unrealized Gain (Loss) on Investments
Net Realized Gain (Loss) on the Sale of Fund Shares		(349,701	)		10,413
Realized Capital Gain Distributions Received		85,290			-
Net Change in Unrealized Appreciation (Depreciation)		833,235			102,366
Net Gain (Loss) on Investments		568,824			112,779
Net Increase (Decrease) in Net Assets Resulting from Operations	$	582,906		$	108,607

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
42

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	AIM CAPITAL APPRECIATION I			AIM CAPITAL APPRECIATION II			AIM CAPITAL DEVELOPMENT SERIES I			AIM CAPITAL DEVELOPMENT SERIES II			AIM GLOBAL HEALTHCARE
Net Assets at January 1, 2008	$	9,234,610		$	768,720		$	434,593		$	787,826		$	936,153
Increase in Net Assets from Operations
Net Investment Income (Loss)		(97,017	)		(12,148	)		(4,658	)		(8,985	)		(10,018	)
Realized Gains (Losses)		(142,892	)		(54,082	)		50,290			34,360			176,825
Net Change in Unrealized Appreciation (Depreciation)		(3,492,415	)		(401,063	)		(251,081	)		(399,632	)		(407,560	)
Net Increase (Decrease) in Net Assets Resulting from Operations		(3,732,324	)		(467,293	)		(205,449	)		(374,257	)		(240,753	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		453,677			567,002			56,436			244,904			54,701
Spinnaker Advisor		27,715			50,978			9,424			2,590			15,498
Spinnaker with EEB		-			-			-			840			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			32,882			-			205			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			235			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(1,219,776	)		(182,496	)		(56,830	)		(238,505	)		(193,858	)
Spinnaker Advisor		(103,056	)		(21,748	)		(13,115	)		(13,834	)		(67,579	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			(28,299	)		-			(1,695	)		-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			(14	)		-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Maintenance Charges
Spinnaker & Mainsail		(2,500	)		(5	)		(60	)		(132	)		-
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		(843,940	)		418,535			(4,145	)		(5,627	)		(191,238	)
Total Increase (Decrease) in Net Assets		(4,576,264	)		(48,758	)		(209,594	)		(379,884	)		(431,991	)
Net Assets at December 31, 2008	$	4,658,346		$	719,962		$	224,999		$	407,942		$	504,162

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
43

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	AIM CAPITAL APPRECIATION I			AIM CAPITAL APPRECIATION II			AIM CAPITAL DEVELOPMENT SERIES I			AIM CAPITAL DEVELOPMENT SERIES II			AIM GLOBAL HEALTHCARE
Net Assets at December 31, 2008	$	4,658,346		$	719,962		$	224,999		$	407,942		$	504,162
Increase in Net Assets from Operations
Net Investment Income (Loss)		(35,162	)		(8,595	)		(3,230	)		(7,111	)		(5,239	)
Realized Gains (Losses)		(458,510	)		(154,807	)		(41,411	)		(147,680	)		(45,575	)
Net Change in Unrealized Appreciation (Depreciation)		1,328,045			304,174			121,275			327,912			162,701
Net Increase (Decrease) in Net Assets Resulting from Operations		834,373			140,772			76,634			173,121			111,887
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		385,522			226,305			15,381			148,145			38,238
Spinnaker Advisor		19,790			9,013			7,715			19,399			2,071
Spinnaker with EEB		-			-			-			630			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			921			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			278			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(771,952	)		(209,082	)		(38,960	)		(100,394	)		(89,604	)
Spinnaker Advisor		(58,677	)		(7,278	)		(10,945	)		(5,695	)		(25,155	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			(695	)		-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			(45	)		-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Maintenance Charges
Spinnaker & Mainsail		(2,067	)		(126	)		(90	)		(70	)		(30	)
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		(427,384	)		19,291			(26,899	)		62,015			(74,480	)
Total Increase (Decrease) in Net Assets		406,989			160,063			49,735			235,136			37,407
Net Assets at December 31, 2009	$	5,065,335		$	880,025		$	274,734		$	643,078		$	541,569

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
44

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	AIM GLOBAL REAL ESTATE			AIM INTERNATIONAL GROWTH I			AIM INTERNATIONAL GROWTH II			AIM SMALL CAP EQUITY II			AMERICAN CENTURY BALANCED
Net Assets at January 1, 2008	$	14,915,650		$	3,155,761		$	6,360,284		$	-		$	16,849,160
Increase in Net Assets from Operations
Net Investment Income (Loss)		431,862			(21,274	)		(51,696	)		(138	)		185,179
Realized Gains (Losses)		1,776,909			168,297			(157,784	)		69			611,318
Net Change in Unrealized Appreciation (Depreciation)		(8,215,405	)		(1,411,841	)		(3,047,430	)		(8,731	)		(4,130,745	)
Net Increase (Decrease) in Net Assets Resulting from Operations		(6,006,634	)		(1,264,818	)		(3,256,910	)		(8,800	)		(3,334,248	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		1,113,410			338,604			3,782,518			13,080			1,487,367
Spinnaker Advisor		286,404			27,808			349,909			19,916			500,578
Spinnaker with EEB		-			-			840			-			1,680
Spinnaker with GMDB		-			-			2,727			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		2,036			2,291			76,662			-			24,379
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		114			-			35			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(3,122,849	)		(372,859	)		(1,054,526	)		-			(3,201,418	)
Spinnaker Advisor		(616,517	)		(168,157	)		(503,914	)		(12	)		(897,547	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			(135	)		-			(60	)
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		(973	)		(2,238	)		(556,796	)		-			(27,358	)
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		(659	)		-			(6	)		-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Maintenance Charges
Spinnaker & Mainsail		(2,842	)		(35	)		(244	)		-			(32,208	)
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		(2,341,876	)		(174,586	)		2,097,070			32,984			(2,144,587	)
Total Increase (Decrease) in Net Assets		(8,348,510	)		(1,439,404	)		(1,159,840	)		24,183			(5,478,835	)
Net Assets at December 31, 2008	$	6,567,140		$	1,716,357		$	5,200,444		$	24,184		$	11,370,325

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
45

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	AIM GLOBAL REAL ESTATE			AIM INTERNATIONAL GROWTH I			AIM INTERNATIONAL GROWTH II			AIM SMALL CAP EQUITY II			AMERICAN CENTURY BALANCED
Net Assets at December 31, 2008	$	6,567,140		$	1,716,357		$	5,200,444		$	24,184		$	11,370,325
Increase in Net Assets from Operations
Net Investment Income (Loss)		(94,096	)		2,767			9,192			(613	)		420,604
Realized Gains (Losses)		(1,604,818	)		(7,925	)		(786,742	)		(5,699	)		(925,032	)
Net Change in Unrealized Appreciation (Depreciation)		3,502,775			549,246			2,731,455			20,222			1,883,337
Net Increase (Decrease) in Net Assets Resulting from Operations		1,803,861			544,088			1,953,905			13,910			1,378,909
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		1,021,058			236,865			2,176,039			39,556			998,973
Spinnaker Advisor		118,772			12,126			366,166			7,219			99,011
Spinnaker with EEB		-			-			630			-			1,260
Spinnaker with GMDB		-			-			1,422			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		4,251			5,217			6,117			-			5,590
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		34			-			35			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(1,092,049	)		(304,256	)		(1,208,383	)		(9,033	)		(1,773,415	)
Spinnaker Advisor		(361,454	)		(46,471	)		(91,944	)		(3,879	)		(553,741	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		(22	)		(34	)		(30	)		-			(25	)
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		(8,208	)		(6,535	)		(10,076	)		-			(14,908	)
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		(64	)		-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Maintenance Charges
Spinnaker & Mainsail		(2,021	)		(41	)		(123	)		-			(23,464	)
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		(319,703	)		(103,129	)		1,239,853			33,863			(1,260,719	)
Total Increase (Decrease) in Net Assets		1,484,158			440,959			3,193,758			47,773			118,190
Net Assets at December 31, 2009	$	8,051,298		$	2,157,316		$	8,394,202		$	71,957		$	11,488,515

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
46

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	AMERICAN CENTURY INFLATION PROTECTION II			AMERICAN CENTURY INTERNATIONAL			AMERICAN CENTURY LARGE COMPANY VALUE II			AMERICAN CENTURY ULTRA I			AMERICAN CENTURY ULTRA II
Net Assets at January 1, 2008	$	3,533,388		$	18,973,619		$	603,071		$	995,906		$	104,779
Increase in Net Assets from Operations
Net Investment Income (Loss)		134,887			(84,477	)		3,958			(7,997	)		(1,598	)
Realized Gains (Losses)		13,734			1,641,897			(41,871	)		75,955			2,807
Net Change in Unrealized Appreciation (Depreciation)		(314,271	)		(9,777,575	)		(175,126	)		(360,292	)		(55,600	)
Net Increase (Decrease) in Net Assets Resulting from Operations		(165,650	)		(8,220,155	)		(213,039	)		(292,334	)		(54,391	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		1,642,705			1,730,929			215,684			98,393			115,566
Spinnaker Advisor		719,461			439,370			4,352			4,270			361
Spinnaker with EEB		-			3,024			-			672			-
Spinnaker with GMDB		-			18			36			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		19,211			27,655			70,000			16			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			35			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(732,797	)		(2,716,072	)		(181,673	)		(369,555	)		(85,412	)
Spinnaker Advisor		(873,030	)		(553,057	)		(87,828	)		(123,233	)		(3,706	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			(4	)		-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		(6,257	)		(234,710	)		-			(255	)		-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		(825	)		-			-			(6	)		-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Maintenance Charges
Spinnaker & Mainsail		(5,618	)		(7,792	)		(150	)		(113	)		(90	)
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		762,850			(1,310,639	)		20,421			(389,776	)		26,719
Total Increase (Decrease) in Net Assets		597,200			(9,530,794	)		(192,618	)		(682,110	)		(27,672	)
Net Assets at December 31, 2008	$	4,130,588		$	9,442,825		$	410,453		$	313,796		$	77,107

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
47

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	AMERICAN CENTURY INFLATION PROTECTION II			AMERICAN CENTURY INTERNATIONAL			AMERICAN CENTURY LARGE COMPANY VALUE II			AMERICAN CENTURY ULTRA I			AMERICAN CENTURY ULTRA II
Net Assets at December 31, 2008	$	4,130,588		$	9,442,825		$	410,453		$	313,796		$	77,107
Increase in Net Assets from Operations
Net Investment Income (Loss)		16,134			64,730			15,177			(3,900	)		(1,060	)
Realized Gains (Losses)		14,548			(736,543	)		(118,338	)		(34,307	)		(19,445	)
Net Change in Unrealized Appreciation (Depreciation)		320,746			3,475,463			180,754			139,721			45,488
Net Increase (Decrease) in Net Assets Resulting from Operations		351,428			2,803,650			77,593			101,514			24,983
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		1,344,188			1,023,173			141,727			62,061			36,377
Spinnaker Advisor		349,181			83,420			11,232			-			52,391
Spinnaker with EEB		-			2,268			-			504			-
Spinnaker with GMDB		-			18			36			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		5,496			1,069			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			35			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(1,050,543	)		(1,680,220	)		(72,083	)		(49,818	)		(24,570	)
Spinnaker Advisor		(333,920	)		(177,460	)		(96,151	)		(13	)		(52,379	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			(276	)		-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		(5,655	)		(19,318	)		(2,879	)		-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		(80	)		-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Maintenance Charges
Spinnaker & Mainsail		(3,595	)		(6,894	)		(126	)		(63	)		(30	)
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		305,072			(774,220	)		(18,244	)		12,706			11,789
Total Increase (Decrease) in Net Assets		656,500			2,029,430			59,349			114,220			36,772
Net Assets at December 31, 2009	$	4,787,088		$	11,472,255		$	469,802		$	428,016		$	113,879

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
48

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	AMERICAN CENTURY VALUE			DREYFUS APPRECIATION			DREYFUS MIDCAP STOCK			DREYFUS QUALITY BOND			DREYFUS SOCIALLY RESPONSIBLE
Net Assets at January 1, 2008	$	4,632,385		$	6,900,884		$	19,747,745		$	7,648,928		$	3,920,956
Increase in Net Assets from Operations
Net Investment Income (Loss)		41,229			33,342			(70,949	)		238,519			(23,315	)
Realized Gains (Losses)		59,469			559,686			1,550,180			(186,255	)		(90,770	)
Net Change in Unrealized Appreciation (Depreciation)		(1,324,773	)		(2,529,687	)		(8,820,760	)		(431,106	)		(1,336,534	)
Net Increase (Decrease) in Net Assets Resulting from Operations		(1,224,075	)		(1,936,659	)		(7,341,529	)		(378,842	)		(1,450,619	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		1,025,053			483,400			1,458,797			587,185			790,747
Spinnaker Advisor		65,113			196,928			529,262			85,809			126,266
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			734			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		1,072			-			1,791			-			52,603
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			136			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(1,288,110	)		(1,293,150	)		(2,952,477	)		(1,585,580	)		(691,829	)
Spinnaker Advisor		(106,374	)		(258,894	)		(1,381,160	)		(543,349	)		(59,311	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			(8	)		-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		(15,641	)		-			(2,226	)		-			(68,180	)
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			(1,826	)		-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Maintenance Charges
Spinnaker & Mainsail		(968	)		(2,333	)		(4,745	)		(12,506	)		(1,736	)
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		(319,855	)		(873,323	)		(2,352,448	)		(1,468,441	)		148,560
Total Increase (Decrease) in Net Assets		(1,543,930	)		(2,809,982	)		(9,693,977	)		(1,847,283	)		(1,302,059	)
Net Assets at December 31, 2008	$	3,088,455		$	4,090,902		$	10,053,768		$	5,801,645		$	2,618,897

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
49

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	AMERICAN CENTURY VALUE			DREYFUS APPRECIATION			DREYFUS MIDCAP STOCK			DREYFUS QUALITY BOND			DREYFUS SOCIALLY RESPONSIBLE
Net Assets at December 31, 2008	$	3,088,455		$	4,090,902		$	10,053,768		$	5,801,645		$	2,618,897
Increase in Net Assets from Operations
Net Investment Income (Loss)		132,468			49,126			2,394			178,777			(13,014	)
Realized Gains (Losses)		(503,852	)		134,339			(2,492,383	)		(197,326	)		(211,828	)
Net Change in Unrealized Appreciation (Depreciation)		974,975			602,510			5,612,663			669,020			1,049,548
Net Increase (Decrease) in Net Assets Resulting from Operations		603,591			785,975			3,122,674			650,471			824,706
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		697,679			275,149			1,107,190			511,187			398,626
Spinnaker Advisor		101,965			75,172			219,278			45,138			86,600
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		1,119			-			6,276			-			3,069
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			30			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(549,674	)		(530,137	)		(1,603,006	)		(1,071,146	)		(571,996	)
Spinnaker Advisor		(63,040	)		(144,903	)		(561,665	)		(404,974	)		(22,866	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			(37	)		-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		(20	)		-			(12,492	)		-			(1,626	)
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			(179	)		-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Maintenance Charges
Spinnaker & Mainsail		(546	)		(1,715	)		(3,534	)		(8,210	)		(1,571	)
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		187,483			(326,434	)		(848,139	)		(928,005	)		(109,764	)
Total Increase (Decrease) in Net Assets		791,074			459,541			2,274,535			(277,534	)		714,942
Net Assets at December 31, 2009	$	3,879,529		$	4,550,443		$	12,328,303		$	5,524,111		$	3,333,839

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
50

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	DREYFUS STOCK INDEX			DREYFUS TECHNOLOGY GROWTH			DWS BALANCED VIP A			DWS CAPITAL GROWTH VIP B			DWS GLOBAL OPPORTUNITIES B SHARE
Net Assets at January 1, 2008	$	19,978,318		$	3,884,032		$	19,449,637		$	-		$	-
Increase in Net Assets from Operations
Net Investment Income (Loss)		58,991			(42,911	)		432,103			(2,591	)		-
Realized Gains (Losses)		570,300			(89,720	)		(509,041	)		(13,904	)		-
Net Change in Unrealized Appreciation (Depreciation)		(8,066,286	)		(1,465,604	)		(4,980,873	)		(119,745	)		3
Net Increase (Decrease) in Net Assets Resulting from Operations		(7,436,995	)		(1,598,235	)		(5,057,811	)		(136,240	)		3
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		3,257,745			646,657			761,979			616,599			30
Spinnaker Advisor		1,242,833			25,325			232,178			5,871			-
Spinnaker with EEB		2,520			-			-			-			-
Spinnaker with GMDB		658			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		63,402			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		341			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(2,943,306	)		(738,258	)		(3,066,804	)		(31,989	)		-
Spinnaker Advisor		(2,170,887	)		(64,540	)		(291,311	)		(204	)		-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		(39	)		-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		(97,813	)		-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		(3,179	)		-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Maintenance Charges
Spinnaker & Mainsail		(8,021	)		(2,005	)		(30,147	)		-			-
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		(655,746	)		(132,821	)		(2,394,105	)		590,277			30
Total Increase (Decrease) in Net Assets		(8,092,741	)		(1,731,056	)		(7,451,916	)		454,037			33
Net Assets at December 31, 2008	$	11,885,577		$	2,152,976		$	11,997,721		$	454,037		$	33

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
51

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	DREYFUS STOCK INDEX			DREYFUS TECHNOLOGY GROWTH			DWS BALANCED VIP A			DWS CAPITAL GROWTH VIP B			DWS GLOBAL OPPORTUNITIES B SHARE
Net Assets at December 31, 2008	$	11,885,577		$	2,152,976		$	11,997,721		$	454,037		$	33
Increase in Net Assets from Operations
Net Investment Income (Loss)		52,440			(24,446	)		288,801			(6,280	)		(149	)
Realized Gains (Losses)		(750,379	)		(202,824	)		(890,045	)		(50,167	)		(15	)
Net Change in Unrealized Appreciation (Depreciation)		3,469,157			1,349,935			2,914,037			333,849			2,961
Net Increase (Decrease) in Net Assets Resulting from Operations		2,771,218			1,122,665			2,312,793			277,402			2,797
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		2,440,882			338,657			480,624			811,736			39,063
Spinnaker Advisor		619,812			119,865			62,539			175,050			18,919
Spinnaker with EEB		1,890			-			-			-			-
Spinnaker with GMDB		708			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		10,885			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		318			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(2,663,828	)		(605,848	)		(1,913,145	)		(174,905	)		(682	)
Spinnaker Advisor		(772,952	)		(22,745	)		(400,211	)		(24,756	)		(2,934	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		(119	)		-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		(37,773	)		-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		(270	)		-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Maintenance Charges
Spinnaker & Mainsail		(6,520	)		(1,758	)		(24,353	)		-			-
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		(406,967	)		(171,829	)		(1,794,546	)		787,125			54,366
Total Increase (Decrease) in Net Assets		2,364,251			950,836			518,247			1,064,527			57,163
Net Assets at December 31, 2009	$	14,249,828		$	3,103,812		$	12,515,968		$	1,518,564		$	57,196

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
52

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	DWS GLOBAL THEMATIC B SHARE			DWS INTERNATIONAL VIP A			DWS SMALL CAP INDEX A SHARE			FEDERATED CAPITAL INCOME			FEDERATED HIGH INCOME BOND
Net Assets at January 1, 2008	$	-		$	9,265,103		$	-		$	2,565,547		$	4,730,825
Increase in Net Assets from Operations
Net Investment Income (Loss)		(20	)		699			(73	)		99,731			342,260
Realized Gains (Losses)		(635	)		1,044,454			(17	)		(185,611	)		(300,259	)
Net Change in Unrealized Appreciation (Depreciation)		232			(5,221,772	)		(4,123	)		(391,798	)		(1,104,287	)
Net Increase (Decrease) in Net Assets Resulting from Operations		(423	)		(4,176,619	)		(4,213	)		(477,678	)		(1,062,286	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		32,738			287,184			-			128,412			136,955
Spinnaker Advisor		-			32,479			-			337			6,787
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			1,273
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			17,879			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(29,087	)		(1,144,128	)		-			(572,778	)		(859,198	)
Spinnaker Advisor		-			(208,108	)		-			(17,931	)		(326,402	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			(90	)		(292	)
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
53

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	DWS GLOBAL THEMATIC B SHARE		DWS INTERNATIONAL VIP A			DWS SMALL CAP INDEX A SHARE		FEDERATED CAPITAL INCOME			FEDERATED HIGH INCOME BOND
Contract Maintenance Charges
Spinnaker & Mainsail	$	-	$	(5,296	)	$	-	$	(6,088	)	$	(9,571	)
Spinnaker Advisor		-		-			-		-			-
Spinnaker with EEB		-		-			-		-			-
Spinnaker with GMDB		-		-			-		-			-
Spinnaker with EEB & GMDB		-		-			-		-			-
Spinnaker Choice		-		-			-		-			-
Spinnaker Choice with EEB		-		-			-		-			-
Spinnaker Choice with GMDB		-		-			-		-			-
Spinnaker Choice with EEB & GMDB		-		-			-		-			-
Focus Tier I		-		-			-		-			-
Focus Tier II		-		-			-		-			-
Focus Tier III		-		-			-		-			-
Focus Tier IV		-		-			-		-			-
Focus Tier V		-		-			-		-			-
Focus Tier I with GMDB		-		-			-		-			-
Focus Tier II with GMDB		-		-			-		-			-
Focus Tier III with GMDB		-		-			-		-			-
Focus Tier IV with GMDB		-		-			-		-			-
Focus Tier V with GMDB		-		-			-		-			-
Increase (Decrease) from Contract Transactions		3,651		(1,037,869	)		17,879		(468,138	)		(1,050,448	)
Total Increase (Decrease) in Net Assets		3,228		(5,214,488	)		13,666		(945,816	)		(2,112,734	)
Net Assets at December 31, 2008	$	3,228	$	4,050,615		$	13,666	$	1,619,731		$	2,618,091

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
54

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	DWS GLOBAL THEMATIC B SHARE			DWS INTERNATIONAL VIP A			DWS SMALL CAP INDEX A SHARE			FEDERATED CAPITAL INCOME			FEDERATED HIGH INCOME BOND
Net Assets at December 31, 2008	$	3,228		$	4,050,615		$	13,666		$	1,619,731		$	2,618,091
Increase in Net Assets from Operations
Net Investment Income (Loss)		(108	)		123,747			(108	)		78,662			300,056
Realized Gains (Losses)		69			(664,302	)		1,092			(189,675	)		(299,970	)
Net Change in Unrealized Appreciation (Depreciation)		4,586			1,682,268			9,186			486,290			1,207,413
Net Increase (Decrease) in Net Assets Resulting from Operations		4,547			1,141,713			10,170			375,277			1,207,499
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		22,211			167,522			-			48,465			186,439
Spinnaker Advisor		-			3,389			-			325			4,360
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			228
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			5,039			-			-
Focus Tier II		-			-			23,371			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			6,933			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(80	)		(640,492	)		-			(390,194	)		(476,525	)
Spinnaker Advisor		-			(52,184	)		-			(8,003	)		(143,997	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			(90	)		(16,275	)
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			(513	)		-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
55

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	DWS GLOBAL THEMATIC B SHARE		DWS INTERNATIONAL VIP A			DWS SMALL CAP INDEX A SHARE		FEDERATED CAPITAL INCOME			FEDERATED HIGH INCOME BOND
Contract Maintenance Charges
Spinnaker & Mainsail	$	-	$	(5,070	)	$	-	$	(3,989	)	$	(7,061	)
Spinnaker Advisor		-		-			-		-			-
Spinnaker with EEB		-		-			-		-			-
Spinnaker with GMDB		-		-			-		-			-
Spinnaker with EEB & GMDB		-		-			-		-			-
Spinnaker Choice		-		-			-		-			-
Spinnaker Choice with EEB		-		-			-		-			-
Spinnaker Choice with GMDB		-		-			-		-			-
Spinnaker Choice with EEB & GMDB		-		-			-		-			-
Focus Tier I		-		-			-		-			-
Focus Tier II		-		-			-		-			-
Focus Tier III		-		-			-		-			-
Focus Tier IV		-		-			-		-			-
Focus Tier V		-		-			-		-			-
Focus Tier I with GMDB		-		-			-		-			-
Focus Tier II with GMDB		-		-			-		-			-
Focus Tier III with GMDB		-		-			-		-			-
Focus Tier IV with GMDB		-		-			-		-			-
Focus Tier V with GMDB		-		-			-		-			-
Increase (Decrease) from Contract Transactions		22,131		(526,835	)		34,830		(353,486	)		(452,831	)
Total Increase (Decrease) in Net Assets		26,678		614,878			45,000		21,791			754,668
Net Assets at December 31, 2009	$	29,906	$	4,665,493		$	58,666	$	1,641,522		$	3,372,759

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
56

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	FEDERATED INTERNATIONAL EQUITY			FIDELITY ASSET MANAGER			FIDELITY CONTRAFUND			FIDELITY EQUITY INCOME			FIDELITY FREEDOM FUNDS 2010 II
Net Assets at January 1, 2008	$	2,081,966		$	477,947		$	39,241,835		$	11,390,598		$	-
Increase in Net Assets from Operations
Net Investment Income (Loss)		(11,138	)		6,712			(130,387	)		104,505			1,204
Realized Gains (Losses)		(87,571	)		48,116			(353,450	)		(544,695	)		398
Net Change in Unrealized Appreciation (Depreciation)		(748,482	)		(220,707	)		(16,320,374	)		(4,536,671	)		(13,161	)
Net Increase (Decrease) in Net Assets Resulting from Operations		(847,191	)		(165,879	)		(16,804,211	)		(4,976,861	)		(11,559	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		73,873			67,800			5,728,999			2,125,970			19,469
Spinnaker Advisor		-			65,411			993,444			298,094			44,431
Spinnaker with EEB		-			-			-			1,176			-
Spinnaker with GMDB		-			-			768			72			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			71,111			9,266			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			279			160			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(422,589	)		(34,890	)		(6,822,209	)		(1,947,105	)		-
Spinnaker Advisor		-			(9,520	)		(767,050	)		(508,451	)		(3,136	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			(42	)		(6	)		-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			(121,701	)		(5,179	)		-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			(26	)		(2,184	)		-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
57

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	FEDERATED INTERNATIONAL EQUITY			FIDELITY ASSET MANAGER			FIDELITY CONTRAFUND			FIDELITY EQUITY INCOME			FIDELITY FREEDOM FUNDS 2010 II
Contract Maintenance Charges
Spinnaker & Mainsail	$	(1,748	)	$	(843	)	$	(41,769	)	$	(1,542	)	$	-
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		(350,464	)		87,958			(958,196	)		(29,729	)		60,764
Total Increase (Decrease) in Net Assets		(1,197,655	)		(77,921	)		(17,762,407	)		(5,006,590	)		49,205
Net Assets at December 31, 2008	$	884,311		$	400,026		$	21,479,428		$	6,384,008		$	49,205

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
58

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	FEDERATED INTERNATIONAL EQUITY			FIDELITY ASSET MANAGER			FIDELITY CONTRAFUND			FIDELITY EQUITY INCOME			FIDELITY FREEDOM FUNDS 2010 II
Net Assets at December 31, 2008	$	884,311		$	400,026		$	21,479,428		$	6,384,008		$	49,205
Increase in Net Assets from Operations
Net Investment Income (Loss)		14,440			4,335			10,871			65,854			2,264
Realized Gains (Losses)		(145,103	)		(22,264	)		(2,278,815	)		(1,359,517	)		289
Net Change in Unrealized Appreciation (Depreciation)		448,234			119,121			9,645,687			3,114,631			15,203
Net Increase (Decrease) in Net Assets Resulting from Operations		317,571			101,192			7,377,743			1,820,968			17,756
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		41,431			37,863			3,657,421			1,369,606			24,159
Spinnaker Advisor		-			1,185			501,993			124,852			8,322
Spinnaker with EEB		-			-			-			882			-
Spinnaker with GMDB		-			-			36			72			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			49,977			7,276			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			93			43			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(254,083	)		(34,807	)		(3,484,241	)		(1,325,608	)		-
Spinnaker Advisor		-			(28,917	)		(272,519	)		(117,135	)		-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			(650	)		(46	)		-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			(26,679	)		(12,711	)		-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			(67	)		(213	)		-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
59

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	FEDERATED INTERNATIONAL EQUITY			FIDELITY ASSET MANAGER			FIDELITY CONTRAFUND			FIDELITY EQUITY INCOME			FIDELITY FREEDOM FUNDS 2010 II
Contract Maintenance Charges
Spinnaker & Mainsail	$	(1,320	)	$	(589	)	$	(35,010	)	$	(1,276	)	$	(30	)
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		(213,972	)		(25,265	)		390,354			45,742			32,451
Total Increase (Decrease) in Net Assets		103,599			75,927			7,768,097			1,866,710			50,207
Net Assets at December 31, 2009	$	987,910		$	475,953		$	29,247,525		$	8,250,718		$	99,412

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
60

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	FIDELITY FREEDOM FUNDS 2015 II			FIDELITY FREEDOM FUNDS 2020 II			FIDELITY FREEDOM FUNDS 2025 II			FIDELITY FREEDOM FUNDS 2030 II			FIDELITY FREEDOM INCOME FUND II
Net Assets at January 1, 2008	$	-		$	-		$	-		$	-		$	-
Increase in Net Assets from Operations
Net Investment Income (Loss)		385			10,892			431			1,139			1,457
Realized Gains (Losses)		490			14,018			914			3,309			300
Net Change in Unrealized Appreciation (Depreciation)		(5,295	)		(42,262	)		(11,318	)		(36,777	)		(6,042	)
Net Increase (Decrease) in Net Assets Resulting from Operations		(4,420	)		(17,352	)		(9,973	)		(32,329	)		(4,285	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		11,029			412,173			-			95,215			50,889
Spinnaker Advisor		9,742			-			31,341			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		-			-			30			(30	)		-
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Maintenance Charges
Spinnaker & Mainsail		(30	)		(30	)		(30	)		-			-
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		20,741			412,143			31,341			95,185			50,889
Total Increase (Decrease) in Net Assets		16,321			394,791			21,368			62,856			46,604
Net Assets at December 31, 2008	$	16,321		$	394,791		$	21,368		$	62,856		$	46,604

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
61

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	FIDELITY FREEDOM FUNDS 2015 II			FIDELITY FREEDOM FUNDS 2020 II			FIDELITY FREEDOM FUNDS 2025 II			FIDELITY FREEDOM FUNDS 2030 II			FIDELITY FREEDOM INCOME FUND II
Net Assets at December 31, 2008	$	16,321		$	394,791		$	21,368		$	62,856		$	46,604
Increase in Net Assets from Operations
Net Investment Income (Loss)		1,426			8,645			4,518			1,442			991
Realized Gains (Losses)		(1,014	)		304			3,103			(36,613	)		78
Net Change in Unrealized Appreciation (Depreciation)		10,258			101,463			45,845			53,990			4,594
Net Increase (Decrease) in Net Assets Resulting from Operations		10,670			110,412			53,466			18,819			5,663
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		38,065			25,851			114,205			64,564			530
Spinnaker Advisor		4,298			7,214			72,237			74,959			3,747
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(3,157	)		(5,775	)		(13,387	)		(49,438	)		(3,964	)
Spinnaker Advisor		-			-			-			(35,570	)		-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Contract Maintenance Charges
Spinnaker & Mainsail		(62	)		(90	)		(180	)		(120	)		-
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		39,144			27,200			172,875			54,395			314
Total Increase (Decrease) in Net Assets		49,814			137,612			226,341			73,214			5,977
Net Assets at December 31, 2009	$	66,135		$	532,403		$	247,709		$	136,070		$	52,581

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
62

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	FIDELITY GROWTH			FIDELITY GROWTH & INCOME			FIDELITY GROWTH OPPORTUNITIES			FIDELITY INDEX 500			FIDELITY MID-CAP ADVISOR II
Net Assets at January 1, 2008	$	22,501,693		$	11,046,609		$	6,172,485		$	43,091		$	7,441,575
Increase in Net Assets from Operations
Net Investment Income (Loss)		(103,740	)		(18,840	)		(44,267	)		4,481			(83,736	)
Realized Gains (Losses)		91,733			886,675			(116,710	)		(12,615	)		572,446
Net Change in Unrealized Appreciation (Depreciation)		(10,302,127	)		(5,497,552	)		(3,009,600	)		(84,925	)		(4,030,294	)
Net Increase (Decrease) in Net Assets Resulting from Operations		(10,314,134	)		(4,629,717	)		(3,170,577	)		(93,059	)		(3,541,584	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		1,493,336			1,138,594			308,806			-			2,459,034
Spinnaker Advisor		351,814			167,078			5,092			-			671,356
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			54			-			-			108
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		1,431			18,967			-			-			12,150
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		70			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			139,706			-
Focus Tier II		-			-			-			79,905			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			165,916			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(2,480,571	)		(1,260,401	)		(946,715	)		-			(1,076,411	)
Spinnaker Advisor		(636,936	)		(430,863	)		(26,226	)		-			(522,949	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		(30	)		(5	)		-			-			(6	)
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		(640	)		(68	)		-			-			(4,728	)
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		(1,074	)		-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			(65,951	)		-
Focus Tier II		-			-			-			(39,741	)		-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
63

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	FIDELITY GROWTH			FIDELITY GROWTH & INCOME			FIDELITY GROWTH OPPORTUNITIES			FIDELITY INDEX 500		FIDELITY MID-CAP ADVISOR II
Contract Maintenance Charges
Spinnaker & Mainsail	$	(14,760	)	$	(10,573	)	$	(4,861	)	$	-	$	(911	)
Spinnaker Advisor		-			-			-			-		-
Spinnaker with EEB		-			-			-			-		-
Spinnaker with GMDB		-			-			-			-		-
Spinnaker with EEB & GMDB		-			-			-			-		-
Spinnaker Choice		-			-			-			-		-
Spinnaker Choice with EEB		-			-			-			-		-
Spinnaker Choice with GMDB		-			-			-			-		-
Spinnaker Choice with EEB & GMDB		-			-			-			-		-
Focus Tier I		-			-			-			-		-
Focus Tier II		-			-			-			-		-
Focus Tier III		-			-			-			-		-
Focus Tier IV		-			-			-			-		-
Focus Tier V		-			-			-			-		-
Focus Tier I with GMDB		-			-			-			-		-
Focus Tier II with GMDB		-			-			-			-		-
Focus Tier III with GMDB		-			-			-			-		-
Focus Tier IV with GMDB		-			-			-			-		-
Focus Tier V with GMDB		-			-			-			-		-
Increase (Decrease) from Contract Transactions		(1,287,360	)		(377,217	)		(663,904	)		279,835		1,537,643
Total Increase (Decrease) in Net Assets		(11,601,494	)		(5,006,934	)		(3,834,481	)		186,776		(2,003,941	)
Net Assets at December 31, 2008	$	10,900,199		$	6,039,675		$	2,338,004		$	229,867	$	5,437,634

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
64

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	FIDELITY GROWTH			FIDELITY GROWTH & INCOME			FIDELITY GROWTH OPPORTUNITIES			FIDELITY INDEX 500			FIDELITY MID-CAP ADVISOR II
Net Assets at December 31, 2008	$	10,900,199		$	6,039,675		$	2,338,004		$	229,867		$	5,437,634
Increase in Net Assets from Operations
Net Investment Income (Loss)		(104,826	)		(19,421	)		(24,408	)		3,674			(60,349	)
Realized Gains (Losses)		(1,079,375	)		(658,416	)		(268,988	)		(51,256	)		(864,056	)
Net Change in Unrealized Appreciation (Depreciation)		3,786,648			2,084,941			1,270,439			113,330			3,028,875
Net Increase (Decrease) in Net Assets Resulting from Operations		2,602,447			1,407,104			977,043			65,748			2,104,470
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		1,104,619			796,741			201,870			-			1,512,175
Spinnaker Advisor		100,358			93,450			5,196			-			274,529
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			54			-			-			108
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		2,620			456			-			-			116
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		92			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			18,279			-
Focus Tier II		-			-			-			26,250			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			116,878			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(1,892,884	)		(1,116,349	)		(442,058	)		-			(1,256,265	)
Spinnaker Advisor		(255,453	)		(297,740	)		(3,824	)		-			(187,701	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		(14	)		-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		(6,335	)		(6,853	)		-			-			(9,656	)
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		(86	)		-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			(417	)		-
Focus Tier II		-			-			-			(4,981	)		-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			(116,878	)		-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
65

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	FIDELITY GROWTH			FIDELITY GROWTH & INCOME			FIDELITY GROWTH OPPORTUNITIES			FIDELITY INDEX 500		FIDELITY MID-CAP ADVISOR II
Contract Maintenance Charges
Spinnaker & Mainsail	$	(11,652	)	$	(7,567	)	$	(3,758	)	$	-	$	(852	)
Spinnaker Advisor		-			-			-			-		-
Spinnaker with EEB		-			-			-			-		-
Spinnaker with GMDB		-			-			-			-		-
Spinnaker with EEB & GMDB		-			-			-			-		-
Spinnaker Choice		-			-			-			-		-
Spinnaker Choice with EEB		-			-			-			-		-
Spinnaker Choice with GMDB		-			-			-			-		-
Spinnaker Choice with EEB & GMDB		-			-			-			-		-
Focus Tier I		-			-			-			-		-
Focus Tier II		-			-			-			-		-
Focus Tier III		-			-			-			-		-
Focus Tier IV		-			-			-			-		-
Focus Tier V		-			-			-			-		-
Focus Tier I with GMDB		-			-			-			-		-
Focus Tier II with GMDB		-			-			-			-		-
Focus Tier III with GMDB		-			-			-			-		-
Focus Tier IV with GMDB		-			-			-			-		-
Focus Tier V with GMDB		-			-			-			-		-
Increase (Decrease) from Contract Transactions		(958,735	)		(537,808	)		(242,574	)		39,131		332,454
Total Increase (Decrease) in Net Assets		1,643,712			869,296			734,469			104,879		2,436,924
Net Assets at December 31, 2009	$	12,543,911		$	6,908,971		$	3,072,473		$	334,746	$	7,874,558

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
66

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	FIDELITY MONEY MARKET FUND			FIDELITY OVERSEAS II			FIDELITY VIP MONEY MARKET SERVICE CLASS			FRANKLIN FLEX CAP GROWTH SECURITIES			FRANKLIN FOUNDING ALLOCATION FUND CLASS II
Net Assets at January 1, 2008	$	880,173		$	-		$	5,741,259		$	254,119		$	-
Increase in Net Assets from Operations
Net Investment Income (Loss)		17,020			1,347			118,614			(2,939	)		3,558
Realized Gains (Losses)		-			(432	)		2			(22,240	)		1,361
Net Change in Unrealized Appreciation (Depreciation)		-			(20,283	)		(2	)		(75,950	)		(51,971	)
Net Increase (Decrease) in Net Assets Resulting from Operations		17,020			(19,368	)		118,614			(101,129	)		(47,052	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		-			19,747			12,842,083			61,939			138,007
Spinnaker Advisor		-			46,050			7,378,078			15			75,586
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			325			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			5,948,096			790			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			176			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		2,694,782			-			-			-			-
Focus Tier II		2,241,371			-			-			-			-
Focus Tier III		1,338,669			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		578,451			-			-			-			-
Focus Tier II with GMDB		500,476			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		-			(499	)		(10,070,613	)		(19,200	)		(1,107	)
Spinnaker Advisor		-			-			(4,153,379	)		(1	)		(7,557	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			(355	)		-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			(5,850,981	)		(45,362	)		-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			(356	)		-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		(2,486,026	)		-			-			-			-
Focus Tier II		(2,089,165	)		-			-			-			-
Focus Tier III		(1,191,017	)		-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		(602,061	)		-			-			-			-
Focus Tier II with GMDB		(620,729	)		-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
67

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	FIDELITY MONEY MARKET FUND			FIDELITY OVERSEAS II		FIDELITY VIP MONEY MARKET SERVICE CLASS			FRANKLIN FLEX CAP GROWTH SECURITIES			FRANKLIN FOUNDING ALLOCATION FUND CLASS II
Contract Maintenance Charges
Spinnaker & Mainsail	$	-		$	-	$	(10,693	)	$	-		$	(60	)
Spinnaker Advisor		-			-		-			-			-
Spinnaker with EEB		-			-		-			-			-
Spinnaker with GMDB		-			-		-			-			-
Spinnaker with EEB & GMDB		-			-		-			-			-
Spinnaker Choice		-			-		-			-			-
Spinnaker Choice with EEB		-			-		-			-			-
Spinnaker Choice with GMDB		-			-		-			-			-
Spinnaker Choice with EEB & GMDB		-			-		-			-			-
Focus Tier I		(40	)		-		-			-			-
Focus Tier II		-			-		-			-			-
Focus Tier III		-			-		-			-			-
Focus Tier IV		-			-		-			-			-
Focus Tier V		-			-		-			-			-
Focus Tier I with GMDB		-			-		-			-			-
Focus Tier II with GMDB		-			-		-			-			-
Focus Tier III with GMDB		-			-		-			-			-
Focus Tier IV with GMDB		-			-		-			-			-
Focus Tier V with GMDB		-			-		-			-			-
Increase (Decrease) from Contract Transactions		364,711			65,298		6,082,561			(1,999	)		204,869
Total Increase (Decrease) in Net Assets		381,731			45,930		6,201,175			(103,128	)		157,817
Net Assets at December 31, 2008	$	1,261,904		$	45,930	$	11,942,434		$	150,991		$	157,817

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
68

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	FIDELITY MONEY MARKET FUND			FIDELITY OVERSEAS II			FIDELITY VIP MONEY MARKET SERVICE CLASS			FRANKLIN FLEX CAP GROWTH SECURITIES			FRANKLIN FOUNDING ALLOCATION FUND CLASS II
Net Assets at December 31, 2008	$	1,261,904		$	45,930		$	11,942,434		$	150,991		$	157,817
Increase in Net Assets from Operations
Net Investment Income (Loss)		(5,963	)		1,348			(129,215	)		(2,904	)		4,677
Realized Gains (Losses)		-			694			-			(13,406	)		(15,858	)
Net Change in Unrealized Appreciation (Depreciation)		-			12,459			-			79,461			76,861
Net Increase (Decrease) in Net Assets Resulting from Operations		(5,963	)		14,501			(129,215	)		63,151			65,680
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		-			107,154			13,069,726			103,442			175,204
Spinnaker Advisor		-			1,375			4,164,405			2,376			-
Spinnaker with EEB		-			-			1,936			-			-
Spinnaker with GMDB		-			-			1,523			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			2,120,572			62			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			58			174			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		1,863,358			-			-			-			-
Focus Tier II		374,362			-			-			-			-
Focus Tier III		692,504			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		176,763			-			-			-			-
Focus Tier II with GMDB		393,640			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		-			(53,528	)		(9,655,573	)		(29,395	)		(24,281	)
Spinnaker Advisor		-			(8,293	)		(6,248,203	)		(25,512	)		(13,511	)
Spinnaker with EEB		-			-			(60	)		-			-
Spinnaker with GMDB		-			-			(90	)		-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			(2,122,941	)		(85	)		-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			(57	)		(35	)		-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		(896,715	)		-			-			-			-
Focus Tier II		(420,371	)		-			-			-			-
Focus Tier III		(576,709	)		-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		(130,196	)		-			-			-			-
Focus Tier II with GMDB		(418,994	)		-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
69

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	FIDELITY MONEY MARKET FUND			FIDELITY OVERSEAS II		FIDELITY VIP MONEY MARKET SERVICE CLASS			FRANKLIN FLEX CAP GROWTH SECURITIES			FRANKLIN FOUNDING ALLOCATION FUND CLASS II
Contract Maintenance Charges
Spinnaker & Mainsail	$	-		$	-	$	(47,955	)	$	(2	)	$	(30	)
Spinnaker Advisor		-			-		-			-			-
Spinnaker with EEB		-			-		-			-			-
Spinnaker with GMDB		-			-		-			-			-
Spinnaker with EEB & GMDB		-			-		-			-			-
Spinnaker Choice		-			-		-			-			-
Spinnaker Choice with EEB		-			-		-			-			-
Spinnaker Choice with GMDB		-			-		-			-			-
Spinnaker Choice with EEB & GMDB		-			-		-			-			-
Focus Tier I		(200	)		-		-			-			-
Focus Tier II		-			-		-			-			-
Focus Tier III		-			-		-			-			-
Focus Tier IV		-			-		-			-			-
Focus Tier V		-			-		-			-			-
Focus Tier I with GMDB		(40	)		-		-			-			-
Focus Tier II with GMDB		-			-		-			-			-
Focus Tier III with GMDB		-			-		-			-			-
Focus Tier IV with GMDB		-			-		-			-			-
Focus Tier V with GMDB		-			-		-			-			-
Increase (Decrease) from Contract Transactions		1,057,402			46,708		1,283,341			51,025			137,382
Total Increase (Decrease) in Net Assets		1,051,439			61,209		1,154,126			114,176			203,062
Net Assets at December 31, 2009	$	2,313,343		$	107,139	$	13,096,560		$	265,167		$	360,879

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
70

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	FRANKLIN INCOME SECURITIES FUND CLASS II			FRANKLIN SMALL CAP VALUE FUND II			FRANKLIN SMALL-MID CAP GROWTH II			FRANKLIN U.S. GOVERNMENT II			IBBOTSON AGGRESSIVE GROWTH CLASS I
Net Assets at January 1, 2008	$	7,337,163		$	4,281,050		$	7,033,119		$	17,537,363		$	58,472
Increase in Net Assets from Operations
Net Investment Income (Loss)		273,386			(11,337	)		(77,518	)		615,125			(699	)
Realized Gains (Losses)		32,866			153,921			681,309			(107,289	)		(6,985	)
Net Change in Unrealized Appreciation (Depreciation)		(2,646,556	)		(1,869,545	)		(3,467,388	)		531,557			(61,810	)
Net Increase (Decrease) in Net Assets Resulting from Operations		(2,340,304	)		(1,726,961	)		(2,863,597	)		1,039,393			(69,494	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		1,673,316			1,594,010			909,239			3,709,135			-
Spinnaker Advisor		235,947			273,982			74,968			2,410,842			-
Spinnaker with EEB		-			-			-			2,688			-
Spinnaker with GMDB		36			764			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		277			26,525			16,348			52,150			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		41			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			125,305
Focus Tier II		-			-			-			-			99,192
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(1,248,009	)		(635,328	)		(1,247,001	)		(3,977,952	)		-
Spinnaker Advisor		(397,435	)		(223,987	)		(321,581	)		(2,804,544	)		-
Spinnaker with EEB		-			-			-			(60	)		-
Spinnaker with GMDB		(70	)		(7	)		-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		(47,689	)		(47,501	)		(15,250	)		(134,391	)		-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		(557	)		-			-			(4,351	)		-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			(54,230	)
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
71

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	FRANKLIN INCOME SECURITIES FUND CLASS II			FRANKLIN SMALL CAP VALUE FUND II			FRANKLIN SMALL-MID CAP GROWTH II			FRANKLIN U.S. GOVERNMENT II			IBBOTSON AGGRESSIVE GROWTH CLASS I
Contract Maintenance Charges
Spinnaker & Mainsail	$	(13,611	)	$	(206	)	$	(5,822	)	$	(54,249	)	$	-
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			(40	)
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		202,246			988,252			(589,099	)		(800,732	)		170,227
Total Increase (Decrease) in Net Assets		(2,138,058	)		(738,709	)		(3,452,696	)		238,661			100,733
Net Assets at December 31, 2008	$	5,199,105		$	3,542,341		$	3,580,423		$	17,776,024		$	159,205

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
72

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	FRANKLIN INCOME SECURITIES FUND CLASS II			FRANKLIN SMALL CAP VALUE FUND II			FRANKLIN SMALL-MID CAP GROWTH II			FRANKLIN U.S. GOVERNMENT II			IBBOTSON AGGRESSIVE GROWTH CLASS I
Net Assets at December 31, 2008	$	5,199,105		$	3,542,341		$	3,580,423		$	17,776,024		$	159,205
Increase in Net Assets from Operations
Net Investment Income (Loss)		396,506			17,883			(57,386	)		388,773			(1,823	)
Realized Gains (Losses)		(631,054	)		(843,882	)		(342,541	)		266,729			(28,663	)
Net Change in Unrealized Appreciation (Depreciation)		1,901,545			2,256,380			1,853,177			(380,453	)		93,605
Net Increase (Decrease) in Net Assets Resulting from Operations		1,666,997			1,430,381			1,453,250			275,049			63,119
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		735,082			2,242,129			705,663			3,584,389			-
Spinnaker Advisor		54,751			380,276			23,720			1,238,571			-
Spinnaker with EEB		-			-			-			2,016			-
Spinnaker with GMDB		36			36			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		2,505			8,729			1,551			218,245			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		138			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			162,763
Focus Tier II		-			-			-			-			7,499
Focus Tier III		-			-			-			-			55,310
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(743,419	)		(1,305,563	)		(740,420	)		(4,310,574	)		-
Spinnaker Advisor		(497,440	)		(107,935	)		(89,852	)		(1,207,816	)		-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		(1,307	)		-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		(250,753	)		(1,259	)		(6,068	)		(101,826	)		-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		(322	)		-			-			(429	)		-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			(15,489	)
Focus Tier II		-			-			-			-			(79,992	)
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
73

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	FRANKLIN INCOME SECURITIES FUND CLASS II			FRANKLIN SMALL CAP VALUE FUND II			FRANKLIN SMALL-MID CAP GROWTH II			FRANKLIN U.S. GOVERNMENT II			IBBOTSON AGGRESSIVE GROWTH CLASS I
Contract Maintenance Charges
Spinnaker & Mainsail	$	(12,648	)	$	(471	)	$	(4,609	)	$	(40,478	)	$	-
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			(140	)
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		(713,377	)		1,215,942			(110,015	)		(617,902	)		129,951
Total Increase (Decrease) in Net Assets		953,620			2,646,323			1,343,235			(342,853	)		193,070
Net Assets at December 31, 2009	$	6,152,725		$	6,188,664		$	4,923,658		$	17,433,171		$	352,275

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
74

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	IBBOTSON AGGRESSIVE GROWTH CLASS II			IBBOTSON BALANCED CLASS I			IBBOTSON BALANCED CLASS II			IBBOTSON CONSERVATIVE CLASS I			IBBOTSON CONSERVATIVE CLASS II
Net Assets at January 1, 2008	$	-		$	456,899		$	-		$	-		$	-
Increase in Net Assets from Operations
Net Investment Income (Loss)		(3,873	)		3,777			(852	)		65			(46	)
Realized Gains (Losses)		(2,940	)		(13,500	)		(10,945	)		(23	)		(3	)
Net Change in Unrealized Appreciation (Depreciation)		(205,702	)		(247,595	)		(15,266	)		(8,327	)		417
Net Increase (Decrease) in Net Assets Resulting from Operations		(212,515	)		(257,318	)		(27,063	)		(8,285	)		368
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		1,124,317			-			351,237			-			15,656
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			347,336			-			42,465			-
Focus Tier II		-			65,375			-			71,891			-
Focus Tier III		-			258,065			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			47,395			-
Focus Tier II with GMDB		-			222,452			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(3,084	)		-			(60,888	)		-			-
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			(209	)		-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			(150,000	)		-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			40			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
75

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	IBBOTSON AGGRESSIVE GROWTH CLASS II			IBBOTSON BALANCED CLASS I			IBBOTSON BALANCED CLASS II			IBBOTSON CONSERVATIVE CLASS I			IBBOTSON CONSERVATIVE CLASS II
Contract Maintenance Charges
Spinnaker & Mainsail	$	(60	)	$	-		$	(270	)	$	-		$	-
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			(42	)		-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			(44	)		-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		1,121,173			742,977			290,079			161,747			15,656
Total Increase (Decrease) in Net Assets		908,658			485,659			263,016			153,462			16,024
Net Assets at December 31, 2008	$	908,658		$	942,558		$	263,016		$	153,462		$	16,024

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
76

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	IBBOTSON AGGRESSIVE GROWTH CLASS II			IBBOTSON BALANCED CLASS I			IBBOTSON BALANCED CLASS II			IBBOTSON CONSERVATIVE CLASS I			IBBOTSON CONSERVATIVE CLASS II
Net Assets at December 31, 2008	$	908,658		$	942,558		$	263,016		$	153,462		$	16,024
Increase in Net Assets from Operations
Net Investment Income (Loss)		(5,861	)		(3,224	)		(3,119	)		(1,155	)		(2,344	)
Realized Gains (Losses)		(18,369	)		(115,215	)		305			(125	)		2,167
Net Change in Unrealized Appreciation (Depreciation)		402,869			284,752			477,955			12,029			41,301
Net Increase (Decrease) in Net Assets Resulting from Operations		378,639			166,313			475,141			10,749			41,124
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		650,035			-			2,657,349			-			246,735
Spinnaker Advisor		22,254			-			356,233			-			288,448
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			135,803			-			3,789			-
Focus Tier II		-			410,268			-			274			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(40,370	)		-			(177,185	)		-			(11,290	)
Spinnaker Advisor		-			-			(8,050	)		-			(23,931	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			(173,850	)		-			-			-
Focus Tier II		-			(48,222	)		-			-			-
Focus Tier III		-			(233,433	)		-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			(5,300	)		-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
77

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	IBBOTSON AGGRESSIVE GROWTH CLASS II			IBBOTSON BALANCED CLASS I			IBBOTSON BALANCED CLASS II			IBBOTSON CONSERVATIVE CLASS I			IBBOTSON CONSERVATIVE CLASS II
Contract Maintenance Charges
Spinnaker & Mainsail	$	(721	)	$	-		$	(1,782	)	$	-		$	(35	)
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			(120	)		-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			(80	)		-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		631,198			90,446			2,826,565			(1,317	)		499,927
Total Increase (Decrease) in Net Assets		1,009,837			256,759			3,301,706			9,432			541,051
Net Assets at December 31, 2009	$	1,918,495		$	1,199,317		$	3,564,722		$	162,894		$	557,075

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
78

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	IBBOTSON GROWTH CLASS I			IBBOTSON GROWTH CLASS II			IBBOTSON INCOME AND GROWTH CLASS I			IBBOTSON INCOME AND GROWTH CLASS II			ING GLOBAL RESOURCES
Net Assets at January 1, 2008	$	73,890		$	-		$	206,492		$	-		$	3,344,687
Increase in Net Assets from Operations
Net Investment Income (Loss)		(4,997	)		(547	)		4,839			(193	)		5,371
Realized Gains (Losses)		(51,383	)		(5,930	)		(1,011	)		(39	)		650,149
Net Change in Unrealized Appreciation (Depreciation)		(159,619	)		(21,172	)		(40,613	)		3,242			(1,784,515	)
Net Increase (Decrease) in Net Assets Resulting from Operations		(215,999	)		(27,649	)		(36,785	)		3,010			(1,128,995	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		-			269,017			-			96,557			176,892
Spinnaker Advisor		-			58,437			-			-			43,678
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		247,904			-			26,784			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		428,271			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		297,394			-			7,208			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		-			(61,157	)		-			(28	)		(724,166	)
Spinnaker Advisor		-			(705	)		-			-			(242,102	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		(40,892	)		-			-			-			-
Focus Tier II		-			-			(11,701	)		-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		(144,557	)		-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
79

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	IBBOTSON GROWTH CLASS I			IBBOTSON GROWTH CLASS II			IBBOTSON INCOME AND GROWTH CLASS I			IBBOTSON INCOME AND GROWTH CLASS II			ING GLOBAL RESOURCES
Contract Maintenance Charges
Spinnaker & Mainsail	$	-		$	(60	)	$	-		$	(30	)	$	(2,097	)
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		(160	)		-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		787,960			265,532			22,291			96,499			(747,795	)
Total Increase (Decrease) in Net Assets		571,961			237,883			(14,494	)		99,509			(1,876,790	)
Net Assets at December 31, 2008	$	645,851		$	237,883		$	191,998		$	99,509		$	1,467,897

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
80

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	IBBOTSON GROWTH CLASS I			IBBOTSON GROWTH CLASS II			IBBOTSON INCOME AND GROWTH CLASS I			IBBOTSON INCOME AND GROWTH CLASS II			ING GLOBAL RESOURCES
Net Assets at December 31, 2008	$	645,851		$	237,883		$	191,998		$	99,509		$	1,467,897
Increase in Net Assets from Operations
Net Investment Income (Loss)		(2,445	)		(1,726	)		(373	)		(859	)		(16,404	)
Realized Gains (Losses)		(120,075	)		4,988			(2,595	)		7,930			(55,089	)
Net Change in Unrealized Appreciation (Depreciation)		155,838			255,379			26,752			61,619			531,586
Net Increase (Decrease) in Net Assets Resulting from Operations		33,318			258,641			23,784			68,690			460,093
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		-			1,305,967			-			709,650			93,173
Spinnaker Advisor		-			171,180			-			201,245			6,433
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		21,245			-			-			-			-
Focus Tier II		14,997			-			16,497			-			-
Focus Tier III		55,310			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		32,166			-			561			-			-
Focus Tier II with GMDB		175,104			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		-			(62,615	)		-			(104,618	)		(240,940	)
Spinnaker Advisor		-			(128,872	)		-			(18,420	)		(49,991	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		(26,575	)		-			-			-			-
Focus Tier II		-			-			(11,703	)		-			-
Focus Tier III		(277,446	)		-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		(175,104	)		-			(547	)		-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
81

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	IBBOTSON GROWTH CLASS I			IBBOTSON GROWTH CLASS II			IBBOTSON INCOME AND GROWTH CLASS I			IBBOTSON INCOME AND GROWTH CLASS II			ING GLOBAL RESOURCES
Contract Maintenance Charges
Spinnaker & Mainsail	$	-		$	(925	)	$	-		$	(360	)	$	(1,927	)
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		(320	)		-			(40	)		-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		(180,623	)		1,284,735			4,768			787,497			(193,252	)
Total Increase (Decrease) in Net Assets		(147,305	)		1,543,376			28,552			856,187			266,841
Net Assets at December 31, 2009	$	498,546		$	1,781,259		$	220,550		$	955,696		$	1,734,738

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
82

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	ING JP MORGAN EMERGING MARKETS EQUITY I			JP MORGAN INSURANCE TRUST INTERNATIONAL EQUITY I1		JP MORGAN INSURANCE TRUST MID-CAP VALUE I1		JP MORGAN INSURANCE TRUST U.S. EQUITY I1		JP MORGAN INTERNATIONAL EQUITY1
Net Assets at January 1, 2008	$	3,085,454		$	-	$	-	$	-	$	11,138,984
Increase in Net Assets from Operations
Net Investment Income (Loss)		27,581			-		-		-		33,330
Realized Gains (Losses)		327,818			-		-		-		1,674,736
Net Change in Unrealized Appreciation (Depreciation)		(1,818,253	)		-		-		-		(6,397,380	)
Net Increase (Decrease) in Net Assets Resulting from Operations		(1,462,854	)		-		-		-		(4,689,314	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		64,665			-		-		-		1,576,577
Spinnaker Advisor		-			-		-		-		226,037
Spinnaker with EEB		-			-		-		-		-
Spinnaker with GMDB		-			-		-		-		-
Spinnaker with EEB & GMDB		-			-		-		-		-
Spinnaker Choice		-			-		-		-		2,579
Spinnaker Choice with EEB		-			-		-		-		-
Spinnaker Choice with GMDB		-			-		-		-		-
Spinnaker Choice with EEB & GMDB		-			-		-		-		-
Focus Tier I		-			-		-		-		-
Focus Tier II		-			-		-		-		-
Focus Tier III		-			-		-		-		-
Focus Tier IV		-			-		-		-		-
Focus Tier V		-			-		-		-		-
Focus Tier I with GMDB		-			-		-		-		-
Focus Tier II with GMDB		-			-		-		-		-
Focus Tier III with GMDB		-			-		-		-		-
Focus Tier IV with GMDB		-			-		-		-		-
Focus Tier V with GMDB		-			-		-		-		-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(419,596	)		-		-		-		(1,481,527	)
Spinnaker Advisor		-			-		-		-		(374,907	)
Spinnaker with EEB		-			-		-		-		-
Spinnaker with GMDB		-			-		-		-		-
Spinnaker with EEB & GMDB		-			-		-		-		-
Spinnaker Choice		-			-		-		-		(4,136	)
Spinnaker Choice with EEB		-			-		-		-		-
Spinnaker Choice with GMDB		-			-		-		-		(4,018	)
Spinnaker Choice with EEB & GMDB		-			-		-		-		-
Focus Tier I		-			-		-		-		-
Focus Tier II		-			-		-		-		-
Focus Tier III		-			-		-		-		-
Focus Tier IV		-			-		-		-		-
Focus Tier V		-			-		-		-		-
Focus Tier I with GMDB		-			-		-		-		-
Focus Tier II with GMDB		-			-		-		-		-
Focus Tier III with GMDB		-			-		-		-		-
Focus Tier IV with GMDB		-			-		-		-		-
Focus Tier V with GMDB		-			-		-		-		-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
83

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	ING JP MORGAN EMERGING MARKETS EQUITY I			JP MORGAN INSURANCE TRUST INTERNATIONAL EQUITY I1		JP MORGAN INSURANCE TRUST MID-CAP VALUE I1		JP MORGAN INSURANCE TRUST U.S. EQUITY I1		JP MORGAN INTERNATIONAL EQUITY1
Contract Maintenance Charges
Spinnaker & Mainsail	$	(890	)	$	-	$	-	$	-	$	(191	)
Spinnaker Advisor		-			-		-		-		-
Spinnaker with EEB		-			-		-		-		-
Spinnaker with GMDB		-			-		-		-		-
Spinnaker with EEB & GMDB		-			-		-		-		-
Spinnaker Choice		-			-		-		-		-
Spinnaker Choice with EEB		-			-		-		-		-
Spinnaker Choice with GMDB		-			-		-		-		-
Spinnaker Choice with EEB & GMDB		-			-		-		-		-
Focus Tier I		-			-		-		-		-
Focus Tier II		-			-		-		-		-
Focus Tier III		-			-		-		-		-
Focus Tier IV		-			-		-		-		-
Focus Tier V		-			-		-		-		-
Focus Tier I with GMDB		-			-		-		-		-
Focus Tier II with GMDB		-			-		-		-		-
Focus Tier III with GMDB		-			-		-		-		-
Focus Tier IV with GMDB		-			-		-		-		-
Focus Tier V with GMDB		-			-		-		-		-
Increase (Decrease) from Contract Transactions		(355,821	)		-		-		-		(59,586	)
Total Increase (Decrease) in Net Assets		(1,818,675	)		-		-		-		(4,748,900	)
Net Assets at December 31, 2008	$	1,266,779		$	-	$	-	$	-	$	6,390,084

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
84

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	ING JP MORGAN EMERGING MARKETS EQUITY I			JP MORGAN INSURANCE TRUST INTERNATIONAL EQUITY I1			JP MORGAN INSURANCE TRUST MID-CAP VALUE I1			JP MORGAN INSURANCE TRUST U.S. EQUITY I1			JP MORGAN INTERNATIONAL EQUITY1
Net Assets at December 31, 2008	$	1,266,779		$	-		$	-		$	-		$	6,390,084
Increase in Net Assets from Operations
Net Investment Income (Loss)		2,860			42,394			(45,619	)		(29,287	)		259,387
Realized Gains (Losses)		62,222			(462,467	)		(340,903	)		(54,387	)		(101,308	)
Net Change in Unrealized Appreciation (Depreciation)		686,935			(1,554,233	)		(903,791	)		(61,387	)		3,767,344
Net Increase (Decrease) in Net Assets Resulting from Operations		752,017			(1,974,306	)		(1,290,313	)		(145,061	)		3,925,423
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		27,130			9,264,633			6,021,967			1,860,078			534,113
Spinnaker Advisor		-			1,418,337			1,159,602			1,875,498			74,630
Spinnaker with EEB		-			-			4,008			-			-
Spinnaker with GMDB		-			462			2,336			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			78,267			56,890			-			688
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			571			-			-			75
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(313,573	)		(965,695	)		(666,744	)		(189,238	)		(9,359,122	)
Spinnaker Advisor		-			(72,542	)		(166,740	)		(127,854	)		(1,490,830	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			(547	)
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			(20,769	)		(785	)		-			(73,815	)
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			(401	)		-			-			(571	)
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
85

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	ING JP MORGAN EMERGING MARKETS EQUITY I			JP MORGAN INSURANCE TRUST INTERNATIONAL EQUITY I1			JP MORGAN INSURANCE TRUST MID-CAP VALUE I1			JP MORGAN INSURANCE TRUST U.S. EQUITY I1		JP MORGAN INTERNATIONAL EQUITY1
Contract Maintenance Charges
Spinnaker & Mainsail	$	(723	)	$	(33	)	$	(13	)	$	-	$	(128	)
Spinnaker Advisor		-			-			-			-		-
Spinnaker with EEB		-			-			-			-		-
Spinnaker with GMDB		-			-			-			-		-
Spinnaker with EEB & GMDB		-			-			-			-		-
Spinnaker Choice		-			-			-			-		-
Spinnaker Choice with EEB		-			-			-			-		-
Spinnaker Choice with GMDB		-			-			-			-		-
Spinnaker Choice with EEB & GMDB		-			-			-			-		-
Focus Tier I		-			-			-			-		-
Focus Tier II		-			-			-			-		-
Focus Tier III		-			-			-			-		-
Focus Tier IV		-			-			-			-		-
Focus Tier V		-			-			-			-		-
Focus Tier I with GMDB		-			-			-			-		-
Focus Tier II with GMDB		-			-			-			-		-
Focus Tier III with GMDB		-			-			-			-		-
Focus Tier IV with GMDB		-			-			-			-		-
Focus Tier V with GMDB		-			-			-			-		-
Increase (Decrease) from Contract Transactions		(287,166	)		9,702,830			6,410,521			3,418,484		(10,315,507	)
Total Increase (Decrease) in Net Assets		464,851			7,728,524			5,120,208			3,273,423		(6,390,084	)
Net Assets at December 31, 2009	$	1,731,630		$	7,728,524		$	5,120,208		$	3,273,423	$	-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
86

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	JP MORGAN MID-CAP VALUE1			JP MORGAN US LARGE CAP CORE EQUITY1			MUTUAL SHARES SECURITIES			NEUBERGER BERMAN AMT GUARDIAN CLASS S			NEUBERGER BERMAN AMT MID CAP GROWTH CLASS S
Net Assets at January 1, 2008	$	8,439,195		$	5,059,566		$	9,801,877		$	-		$	-
Increase in Net Assets from Operations
Net Investment Income (Loss)		(19,216	)		(1,549	)		136,069			96			(867	)
Realized Gains (Losses)		520,084			43,506			532,604			1,242			(4,949	)
Net Change in Unrealized Appreciation (Depreciation)		(3,035,910	)		(1,650,612	)		(4,467,012	)		(15,974	)		(53,015	)
Net Increase (Decrease) in Net Assets Resulting from Operations		(2,535,042	)		(1,608,655	)		(3,798,339	)		(14,636	)		(58,831	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		941,451			155,073			1,824,729			48,824			229,914
Spinnaker Advisor		75,891			154,331			209,157			80			186
Spinnaker with EEB		1,176			-			-			-			-
Spinnaker with GMDB		72			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		17,685			-			277			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(1,623,097	)		(536,490	)		(1,621,521	)		(1,117	)		(23,291	)
Spinnaker Advisor		(642,109	)		(448,534	)		(216,875	)		(4	)		-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		(3	)		-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		(6,866	)		-			(9,609	)		-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
87

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	JP MORGAN MID-CAP VALUE1			JP MORGAN US LARGE CAP CORE EQUITY1			MUTUAL SHARES SECURITIES			NEUBERGER BERMAN AMT GUARDIAN CLASS S		NEUBERGER BERMAN AMT MID CAP GROWTH CLASS S
Contract Maintenance Charges
Spinnaker & Mainsail	$	(721	)	$	(4,335	)	$	(5,534	)	$	-	$	-
Spinnaker Advisor		-			-			-			-		-
Spinnaker with EEB		-			-			-			-		-
Spinnaker with GMDB		-			-			-			-		-
Spinnaker with EEB & GMDB		-			-			-			-		-
Spinnaker Choice		-			-			-			-		-
Spinnaker Choice with EEB		-			-			-			-		-
Spinnaker Choice with GMDB		-			-			-			-		-
Spinnaker Choice with EEB & GMDB		-			-			-			-		-
Focus Tier I		-			-			-			-		-
Focus Tier II		-			-			-			-		-
Focus Tier III		-			-			-			-		-
Focus Tier IV		-			-			-			-		-
Focus Tier V		-			-			-			-		-
Focus Tier I with GMDB		-			-			-			-		-
Focus Tier II with GMDB		-			-			-			-		-
Focus Tier III with GMDB		-			-			-			-		-
Focus Tier IV with GMDB		-			-			-			-		-
Focus Tier V with GMDB		-			-			-			-		-
Increase (Decrease) from Contract Transactions		(1,236,521	)		(679,955	)		180,624			47,783		206,809
Total Increase (Decrease) in Net Assets		(3,771,563	)		(2,288,610	)		(3,617,715	)		33,147		147,978
Net Assets at December 31, 2008	$	4,667,632		$	2,770,956		$	6,184,162		$	33,147	$	147,978

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
88

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	JP MORGAN MID-CAP VALUE1			JP MORGAN US LARGE CAP CORE EQUITY1			MUTUAL SHARES SECURITIES			NEUBERGER BERMAN AMT GUARDIAN CLASS S			NEUBERGER BERMAN AMT MID CAP GROWTH CLASS S
Net Assets at December 31, 2008	$	4,667,632		$	2,770,956		$	6,184,162		$	33,147		$	147,978
Increase in Net Assets from Operations
Net Investment Income (Loss)		87,566			54,206			36,437			(132	)		(3,743	)
Realized Gains (Losses)		(309,921	)		(61,001	)		(553,024	)		(5,639	)		(18,288	)
Net Change in Unrealized Appreciation (Depreciation)		2,529,366			935,542			2,021,872			15,237			104,652
Net Increase (Decrease) in Net Assets Resulting from Operations		2,307,011			928,747			1,505,285			9,466			82,621
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		181,142			33,341			1,129,699			16,058			174,543
Spinnaker Advisor		15,084			21,329			178,137			130			35,302
Spinnaker with EEB		392			-			-			-			-
Spinnaker with GMDB		24			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			4,439			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(5,879,533	)		(1,873,174	)		(1,030,325	)		(10,981	)		(45,940	)
Spinnaker Advisor		(1,228,455	)		(1,878,008	)		(83,171	)		-			(8,431	)
Spinnaker with EEB		(3,518	)		-			-			-			-
Spinnaker with GMDB		(2,288	)		-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		(56,890	)		-			(2,866	)		-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
89

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	JP MORGAN MID-CAP VALUE1			JP MORGAN US LARGE CAP CORE EQUITY1			MUTUAL SHARES SECURITIES			NEUBERGER BERMAN AMT GUARDIAN CLASS S		NEUBERGER BERMAN AMT MID CAP GROWTH CLASS S
Contract Maintenance Charges
Spinnaker & Mainsail	$	(601	)	$	(3,191	)	$	(4,991	)	$	-	$	-
Spinnaker Advisor		-			-			-			-		-
Spinnaker with EEB		-			-			-			-		-
Spinnaker with GMDB		-			-			-			-		-
Spinnaker with EEB & GMDB		-			-			-			-		-
Spinnaker Choice		-			-			-			-		-
Spinnaker Choice with EEB		-			-			-			-		-
Spinnaker Choice with GMDB		-			-			-			-		-
Spinnaker Choice with EEB & GMDB		-			-			-			-		-
Focus Tier I		-			-			-			-		-
Focus Tier II		-			-			-			-		-
Focus Tier III		-			-			-			-		-
Focus Tier IV		-			-			-			-		-
Focus Tier V		-			-			-			-		-
Focus Tier I with GMDB		-			-			-			-		-
Focus Tier II with GMDB		-			-			-			-		-
Focus Tier III with GMDB		-			-			-			-		-
Focus Tier IV with GMDB		-			-			-			-		-
Focus Tier V with GMDB		-			-			-			-		-
Increase (Decrease) from Contract Transactions		(6,974,643	)		(3,699,703	)		190,922			5,207		155,474
Total Increase (Decrease) in Net Assets		(4,667,632	)		(2,770,956	)		1,696,207			14,673		238,095
Net Assets at December 31, 2009	$	-		$	-		$	7,880,369		$	47,820	$	386,073

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
90

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	NEUBERGER BERMAN AMT REGENCY CLASS S		PIMCO ALL ASSET PORTFOLIO ADVISOR			PIMCO COMMODITY FUND ADMIN			PIONEER BOND VCT CLASS I			PIONEER EMERGING MARKETS VCT CLASS II
Net Assets at January 1, 2008	$	-	$	195,600		$	3,140,479		$	6,470,361		$	4,585,492
Increase in Net Assets from Operations
Net Investment Income (Loss)		-		11,758			106,033			231,226			(47,534	)
Realized Gains (Losses)		-		188			296,479			(116,773	)		206,774
Net Change in Unrealized Appreciation (Depreciation)		-		(56,776	)		(2,031,554	)		(231,109	)		(3,079,772	)
Net Increase (Decrease) in Net Assets Resulting from Operations		-		(44,830	)		(1,629,042	)		(116,656	)		(2,920,532	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		-		193,416			1,909,808			355,902			1,667,550
Spinnaker Advisor		-		4,665			436,739			41,506			654,750
Spinnaker with EEB		-		-			672			-			-
Spinnaker with GMDB		-		-			-			-			36
Spinnaker with EEB & GMDB		-		-			-			-			-
Spinnaker Choice		-		-			128,007			-			32,817
Spinnaker Choice with EEB		-		-			-			-			-
Spinnaker Choice with GMDB		-		-			475			-			-
Spinnaker Choice with EEB & GMDB		-		-			-			-			-
Focus Tier I		-		-			-			-			-
Focus Tier II		-		-			-			-			-
Focus Tier III		-		-			-			-			-
Focus Tier IV		-		-			-			-			-
Focus Tier V		-		-			-			-			-
Focus Tier I with GMDB		-		-			-			-			-
Focus Tier II with GMDB		-		-			-			-			-
Focus Tier III with GMDB		-		-			-			-			-
Focus Tier IV with GMDB		-		-			-			-			-
Focus Tier V with GMDB		-		-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		-		(110,217	)		(1,277,385	)		(1,269,861	)		(1,176,785	)
Spinnaker Advisor		-		-			(575,980	)		(256,114	)		(617,923	)
Spinnaker with EEB		-		-			-			-			-
Spinnaker with GMDB		-		-			-			-			(30	)
Spinnaker with EEB & GMDB		-		-			-			-			-
Spinnaker Choice		-		(4	)		(36,842	)		-			(319,868	)
Spinnaker Choice with EEB		-		-			-			-			-
Spinnaker Choice with GMDB		-		-			(2,161	)		-			-
Spinnaker Choice with EEB & GMDB		-		-			-			-			-
Focus Tier I		-		-			-			-			-
Focus Tier II		-		-			-			-			-
Focus Tier III		-		-			-			-			-
Focus Tier IV		-		-			-			-			-
Focus Tier V		-		-			-			-			-
Focus Tier I with GMDB		-		-			-			-			-
Focus Tier II with GMDB		-		-			-			-			-
Focus Tier III with GMDB		-		-			-			-			-
Focus Tier IV with GMDB		-		-			-			-			-
Focus Tier V with GMDB

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
91

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	NEUBERGER BERMAN AMT REGENCY CLASS S		PIMCO ALL ASSET PORTFOLIO ADVISOR			PIMCO COMMODITY FUND ADMIN			PIONEER BOND VCT CLASS I			PIONEER EMERGING MARKETS VCT CLASS II
Contract Maintenance Charges
Spinnaker & Mainsail	$	-	$	(480	)	$	(701	)	$	(15,535	)	$	(258	)
Spinnaker Advisor		-		-			-			-			-
Spinnaker with EEB		-		-			-			-			-
Spinnaker with GMDB		-		-			-			-			-
Spinnaker with EEB & GMDB		-		-			-			-			-
Spinnaker Choice		-		-			-			-			-
Spinnaker Choice with EEB		-		-			-			-			-
Spinnaker Choice with GMDB		-		-			-			-			-
Spinnaker Choice with EEB & GMDB		-		-			-			-			-
Focus Tier I		-		-			-			-			-
Focus Tier II		-		-			-			-			-
Focus Tier III		-		-			-			-			-
Focus Tier IV		-		-			-			-			-
Focus Tier V		-		-			-			-			-
Focus Tier I with GMDB		-		-			-			-			-
Focus Tier II with GMDB		-		-			-			-			-
Focus Tier III with GMDB		-		-			-			-			-
Focus Tier IV with GMDB		-		-			-			-			-
Focus Tier V with GMDB		-		-			-			-			-
Increase (Decrease) from Contract Transactions		-		87,380			582,632			(1,144,102	)		240,289
Total Increase (Decrease) in Net Assets		-		42,550			(1,046,410	)		(1,260,758	)		(2,680,243	)
Net Assets at December 31, 2008	$	-	$	238,150		$	2,094,069		$	5,209,603		$	1,905,249

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
92

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	NEUBERGER BERMAN AMT REGENCY CLASS S		PIMCO ALL ASSET PORTFOLIO ADVISOR			PIMCO COMMODITY FUND ADMIN			PIONEER BOND VCT CLASS I			PIONEER EMERGING MARKETS VCT CLASS II
Net Assets at December 31, 2008	$	-	$	238,150		$	2,094,069		$	5,209,603		$	1,905,249
Increase in Net Assets from Operations
Net Investment Income (Loss)		4		23,374			134,421			213,934			(14,887	)
Realized Gains (Losses)		155		(17,074	)		(125,969	)		(70,813	)		(751,329	)
Net Change in Unrealized Appreciation (Depreciation)		2,830		87,220			962,330			612,985			2,263,867
Net Increase (Decrease) in Net Assets Resulting from Operations		2,989		93,520			970,782			756,106			1,497,651
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		13,586		277,577			950,339			217,959			946,505
Spinnaker Advisor		-		2,646			262,775			23,913			194,295
Spinnaker with EEB		-		-			504			-			-
Spinnaker with GMDB		-		-			-			-			36
Spinnaker with EEB & GMDB		-		-			-			-			-
Spinnaker Choice		-		-			8,842			-			153
Spinnaker Choice with EEB		-		-			-			-			-
Spinnaker Choice with GMDB		-		-			73			-			-
Spinnaker Choice with EEB & GMDB		-		-			-			-			-
Focus Tier I		-		-			-			-			-
Focus Tier II		-		-			-			-			-
Focus Tier III		-		-			-			-			-
Focus Tier IV		-		-			-			-			-
Focus Tier V		-		-			-			-			-
Focus Tier I with GMDB		-		-			-			-			-
Focus Tier II with GMDB		-		-			-			-			-
Focus Tier III with GMDB		-		-			-			-			-
Focus Tier IV with GMDB		-		-			-			-			-
Focus Tier V with GMDB		-		-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		-		(162,692	)		(501,947	)		(799,221	)		(717,516	)
Spinnaker Advisor		-		-			(139,517	)		(183,199	)		(50,954	)
Spinnaker with EEB		-		-			-			-			-
Spinnaker with GMDB		-		-			(22	)		-			(30	)
Spinnaker with EEB & GMDB		-		-			-			-			-
Spinnaker Choice		-		(5	)		(50,940	)		-			(12,344	)
Spinnaker Choice with EEB		-		-			-			-			-
Spinnaker Choice with GMDB		-		-			(193	)		-			-
Spinnaker Choice with EEB & GMDB		-		-			-			-			-
Focus Tier I		-		-			-			-			-
Focus Tier II		-		-			-			-			-
Focus Tier III		-		-			-			-			-
Focus Tier IV		-		-			-			-			-
Focus Tier V		-		-			-			-			-
Focus Tier I with GMDB		-		-			-			-			-
Focus Tier II with GMDB		-		-			-			-			-
Focus Tier III with GMDB		-		-			-			-			-
Focus Tier IV with GMDB		-		-			-			-			-
Focus Tier V with GMDB		-		-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
93

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	NEUBERGER BERMAN AMT REGENCY CLASS S		PIMCO ALL ASSET PORTFOLIO ADVISOR			PIMCO COMMODITY FUND ADMIN			PIONEER BOND VCT CLASS I			PIONEER EMERGING MARKETS VCT CLASS II
Contract Maintenance Charges
Spinnaker & Mainsail	$	-	$	(180	)	$	(676	)	$	(11,760	)	$	(452	)
Spinnaker Advisor		-		-			-			-			-
Spinnaker with EEB		-		-			-			-			-
Spinnaker with GMDB		-		-			-			-			-
Spinnaker with EEB & GMDB		-		-			-			-			-
Spinnaker Choice		-		-			-			-			-
Spinnaker Choice with EEB		-		-			-			-			-
Spinnaker Choice with GMDB		-		-			-			-			-
Spinnaker Choice with EEB & GMDB		-		-			-			-			-
Focus Tier I		-		-			-			-			-
Focus Tier II		-		-			-			-			-
Focus Tier III		-		-			-			-			-
Focus Tier IV		-		-			-			-			-
Focus Tier V		-		-			-			-			-
Focus Tier I with GMDB		-		-			-			-			-
Focus Tier II with GMDB		-		-			-			-			-
Focus Tier III with GMDB		-		-			-			-			-
Focus Tier IV with GMDB		-		-			-			-			-
Focus Tier V with GMDB		-		-			-			-			-
Increase (Decrease) from Contract Transactions		13,586		117,346			529,238			(752,308	)		359,693
Total Increase (Decrease) in Net Assets		16,575		210,866			1,500,020			3,798			1,857,344
Net Assets at December 31, 2009	$	16,575	$	449,016		$	3,594,089		$	5,213,401		$	3,762,593

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
94

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	PIONEER EQUITY INCOME VCT CLASS II			PIONEER FUND VCT CLASS I			PIONEER GROWTH OPPORTUNITIES VCT CLASS I			PIONEER HIGH YIELD VCT CLASS II			PIONEER MID-CAP VALUE VCT CLASS I
Net Assets at January 1, 2008	$	3,488,173		$	69,163,196		$	59,275,457		$	948,468		$	14,725,233
Increase in Net Assets from Operations
Net Investment Income (Loss)		39,756			228,129			(629,274	)		100,913			(31,181	)
Realized Gains (Losses)		(24,899	)		1,413,392			2,440,731			(164,645	)		(281,179	)
Net Change in Unrealized Appreciation (Depreciation)		(1,199,873	)		(23,808,456	)		(21,615,111	)		(427,339	)		(4,327,336	)
Net Increase (Decrease) in Net Assets Resulting from Operations		(1,185,016	)		(22,166,935	)		(19,803,654	)		(491,071	)		(4,639,696	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		1,256,082			2,131,601			1,845,417			524,538			668,052
Spinnaker Advisor		79,923			47,621			78,461			36,555			12,006
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		36			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		54,461			-			-			5,306,303			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(903,216	)		(10,767,484	)		(9,152,797	)		(277,916	)		(2,543,293	)
Spinnaker Advisor		(130,081	)		(126,283	)		(404,373	)		(50,863	)		(96,328	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			(1	)		-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		(37,970	)		-			-			(4,248,974	)		-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
95

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	PIONEER EQUITY INCOME VCT CLASS II			PIONEER FUND VCT CLASS I			PIONEER GROWTH OPPORTUNITIES VCT CLASS I			PIONEER HIGH YIELD VCT CLASS II			PIONEER MID-CAP VALUE VCT CLASS I
Contract Maintenance Charges
Spinnaker & Mainsail	$	(304	)	$	(47,509	)	$	(17,900	)	$	(1,420	)	$	(3,613	)
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		318,931			(8,762,054	)		(7,651,192	)		1,288,222			(1,963,176	)
Total Increase (Decrease) in Net Assets		(866,085	)		(30,928,989	)		(27,454,846	)		797,151			(6,602,872	)
Net Assets at December 31, 2008	$	2,622,088		$	38,234,207		$	31,820,611		$	1,745,619		$	8,122,361

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
96

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	PIONEER EQUITY INCOME VCT CLASS II			PIONEER FUND VCT CLASS I			PIONEER GROWTH OPPORTUNITIES VCT CLASS I			PIONEER HIGH YIELD VCT CLASS II			PIONEER MID-CAP VALUE VCT CLASS I
Net Assets at December 31, 2008	$	2,622,088		$	38,234,207		$	31,820,611		$	1,745,619		$	8,122,361
Increase in Net Assets from Operations
Net Investment Income (Loss)		51,429			151,148			(489,576	)		93,289			12,209
Realized Gains (Losses)		(584,135	)		(2,909,025	)		(2,156,347	)		(110,298	)		(1,208,806	)
Net Change in Unrealized Appreciation (Depreciation)		995,539			10,722,600			15,256,684			667,344			2,927,078
Net Increase (Decrease) in Net Assets Resulting from Operations		462,833			7,964,723			12,610,761			650,335			1,730,481
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		1,231,071			1,417,573			1,206,745			565,236			329,599
Spinnaker Advisor		137,376			31,045			39,014			199,035			6,054
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		36			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		2,766			-			-			983,392			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(646,352	)		(6,152,247	)		(4,705,580	)		(472,354	)		(1,309,569	)
Spinnaker Advisor		(86,189	)		(98,845	)		(242,169	)		(101,439	)		(37,931	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			(188	)		-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		(7,935	)		-			-			(2,062,335	)		-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
97

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	PIONEER EQUITY INCOME VCT CLASS II			PIONEER FUND VCT CLASS I			PIONEER GROWTH OPPORTUNITIES VCT CLASS I			PIONEER HIGH YIELD VCT CLASS II			PIONEER MID-CAP VALUE VCT CLASS I
Contract Maintenance Charges
Spinnaker & Mainsail	$	(3,776	)	$	(41,516	)	$	(16,133	)	$	(1,034	)	$	(3,001	)
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		626,997			(4,843,990	)		(3,718,123	)		(889,687	)		(1,014,848	)
Total Increase (Decrease) in Net Assets		1,089,830			3,120,733			8,892,638			(239,352	)		715,633
Net Assets at December 31, 2009	$	3,711,918		$	41,354,940		$	40,713,249		$	1,506,267		$	8,837,994

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
98

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	PIONEER MONEY MARKET VCT CLASS I			PIONEER REAL ESTATE VCT CLASS II			PIONEER SMALL-CAP VALUE VCT CLASS I1			PIONEER SMALL-CAP VALUE VCT CLASS II1			PIONEER STRATEGIC INCOME VCT CLASS II
Net Assets at January 1, 2008	$	4,616,178		$	2,035,979		$	14,166,992		$	3,521,587		$	1,860,307
Increase in Net Assets from Operations
Net Investment Income (Loss)		42,131			58,259			(83,162	)		(33,008	)		124,569
Realized Gains (Losses)		-			(91,304	)		432,787			(274,013	)		(45,378	)
Net Change in Unrealized Appreciation (Depreciation)		-			(953,472	)		(5,048,887	)		(971,256	)		(455,467	)
Net Increase (Decrease) in Net Assets Resulting from Operations		42,131			(986,517	)		(4,699,262	)		(1,278,277	)		(376,276	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		339,353			1,152,247			552,481			578,352			1,348,552
Spinnaker Advisor		39,102			306,305			97,533			140,592			669,495
Spinnaker with EEB		-			672			-			840			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			35,326			-			3,158			34,914
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			120			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(939,413	)		(711,382	)		(2,848,215	)		(654,658	)		(572,370	)
Spinnaker Advisor		(96,754	)		(144,999	)		(646,356	)		(384,719	)		(467,333	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			(29,668	)		-			(9,088	)		(48,667	)
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			(676	)		-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
99

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	PIONEER MONEY MARKET VCT CLASS I			PIONEER REAL ESTATE VCT CLASS II			PIONEER SMALL-CAP VALUE VCT CLASS I1			PIONEER SMALL-CAP VALUE VCT CLASS II1			PIONEER STRATEGIC INCOME VCT CLASS II
Contract Maintenance Charges
Spinnaker & Mainsail	$	(17,233	)	$	(431	)	$	(803	)	$	(330	)	$	(2,927	)
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		(674,945	)		608,070			(2,845,360	)		(326,409	)		961,664
Total Increase (Decrease) in Net Assets		(632,814	)		(378,447	)		(7,544,622	)		(1,604,686	)		585,388
Net Assets at December 31, 2008	$	3,983,364		$	1,657,532		$	6,622,370		$	1,916,901		$	2,445,695

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
100

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	PIONEER MONEY MARKET VCT CLASS I			PIONEER REAL ESTATE VCT CLASS II			PIONEER SMALL-CAP VALUE VCT CLASS I1			PIONEER SMALL-CAP VALUE VCT CLASS II1			PIONEER STRATEGIC INCOME VCT CLASS II
Net Assets at December 31, 2008	$	3,983,364		$	1,657,532		$	6,622,370		$	1,916,901		$	2,445,695
Increase in Net Assets from Operations
Net Investment Income (Loss)		(45,424	)		65,889			34,856			3,545			191,445
Realized Gains (Losses)		-			(1,113,017	)		(8,409,384	)		(1,973,509	)		17,366
Net Change in Unrealized Appreciation (Depreciation)		-			1,835,835			7,976,090			1,860,084			479,134
Net Increase (Decrease) in Net Assets Resulting from Operations		(45,424	)		788,707			(398,438	)		(109,880	)		687,945
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		427,269			962,307			157,778			142,427			1,527,725
Spinnaker Advisor		61,797			110,183			28,837			13,451			294,253
Spinnaker with EEB		-			504			-			280			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			1,069			-			995			17,339
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			10			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(765,633	)		(704,077	)		(5,387,170	)		(1,668,932	)		(573,155	)
Spinnaker Advisor		(83,505	)		(73,613	)		(1,022,017	)		(273,081	)		(184,104	)
Spinnaker with EEB		-			-			-			(1,586	)		-
Spinnaker with GMDB		-			-			(1,178	)		(362	)		-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			(2,203	)		-			(20,048	)		(3,648	)
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			(58	)		-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
101

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	PIONEER MONEY MARKET VCT CLASS I			PIONEER REAL ESTATE VCT CLASS II			PIONEER SMALL-CAP VALUE VCT CLASS I1			PIONEER SMALL-CAP VALUE VCT CLASS II1			PIONEER STRATEGIC INCOME VCT CLASS II
Contract Maintenance Charges
Spinnaker & Mainsail	$	(13,156	)	$	(310	)	$	(182	)	$	(117	)	$	(3,917	)
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		(373,228	)		293,860			(6,223,932	)		(1,807,021	)		1,074,493
Total Increase (Decrease) in Net Assets		(418,652	)		1,082,567			(6,622,370	)		(1,916,901	)		1,762,438
Net Assets at December 31, 2009	$	3,564,712		$	2,740,099		$	-		$	-		$	4,208,133

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
102

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	SUMMIT BALANCE INDEX			SUMMIT BARCLAYS AGGREGATE BOND INDEX			SUMMIT EAFE INTERNATIONAL INDEX F CLASS			SUMMIT NASDAQ 100 INDEX			SUMMIT RUSSELL 2000 SMALL CAP INDEX F CLASS
Net Assets at January 1, 2008	$	-		$	-		$	-		$	-		$	-
Increase in Net Assets from Operations
Net Investment Income (Loss)		14			3,617			-			(21	)		(323	)
Realized Gains (Losses)		(8	)		(256	)		-			(5	)		(2,230	)
Net Change in Unrealized Appreciation (Depreciation)		(344	)		8,467			(19	)		(1,330	)		(52,156	)
Net Increase (Decrease) in Net Assets Resulting from Operations		(338	)		11,828			(19	)		(1,356	)		(54,709	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		2,749			306,556			156			9,783			213,655
Spinnaker Advisor		-			15,677			-			-			33,207
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		-			(42,198	)		-			-			(20,521	)
Spinnaker Advisor		-			(1,095	)		-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
103

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	SUMMIT BALANCE INDEX		SUMMIT BARCLAYS AGGREGATE BOND INDEX			SUMMIT EAFE INTERNATIONAL INDEX F CLASS		SUMMIT NASDAQ 100 INDEX			SUMMIT RUSSELL 2000 SMALL CAP INDEX F CLASS
Contract Maintenance Charges
Spinnaker & Mainsail	$	-	$	(1,469	)	$	-	$	(11	)	$	(1	)
Spinnaker Advisor		-		-			-		-			-
Spinnaker with EEB		-		-			-		-			-
Spinnaker with GMDB		-		-			-		-			-
Spinnaker with EEB & GMDB		-		-			-		-			-
Spinnaker Choice		-		-			-		-			-
Spinnaker Choice with EEB		-		-			-		-			-
Spinnaker Choice with GMDB		-		-			-		-			-
Spinnaker Choice with EEB & GMDB		-		-			-		-			-
Focus Tier I		-		-			-		-			-
Focus Tier II		-		-			-		-			-
Focus Tier III		-		-			-		-			-
Focus Tier IV		-		-			-		-			-
Focus Tier V		-		-			-		-			-
Focus Tier I with GMDB		-		-			-		-			-
Focus Tier II with GMDB		-		-			-		-			-
Focus Tier III with GMDB		-		-			-		-			-
Focus Tier IV with GMDB		-		-			-		-			-
Focus Tier V with GMDB		-		-			-		-			-
Increase (Decrease) from Contract Transactions		2,749		277,471			156		9,772			226,340
Total Increase (Decrease) in Net Assets		2,411		289,299			137		8,416			171,631
Net Assets at December 31, 2008	$	2,411	$	289,299		$	137	$	8,416		$	171,631

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
104

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	SUMMIT BALANCE INDEX			SUMMIT BARCLAYS AGGREGATE BOND INDEX			SUMMIT EAFE INTERNATIONAL INDEX F CLASS			SUMMIT NASDAQ 100 INDEX			SUMMIT RUSSELL 2000 SMALL CAP INDEX F CLASS
Net Assets at December 31, 2008	$	2,411		$	289,299		$	137		$	8,416		$	171,631
Increase in Net Assets from Operations
Net Investment Income (Loss)		744			43,137			358			(685	)		(5,353	)
Realized Gains (Losses)		5,317			10,141			2,892			736			(28,006	)
Net Change in Unrealized Appreciation (Depreciation)		5,882			(33,447	)		341			22,803			215,921
Net Increase (Decrease) in Net Assets Resulting from Operations		11,943			19,831			3,591			22,854			182,562
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		103,883			780,238			30,825			84,025			441,064
Spinnaker Advisor		105,345			147,789			63,191			5,128			103,660
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(53,789	)		(94,560	)		(12,373	)		(34,173	)		(93,559	)
Spinnaker Advisor		(105,509	)		(14,080	)		-			-			(17,596	)
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			-
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
105

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	SUMMIT BALANCE INDEX			SUMMIT BARCLAYS AGGREGATE BOND INDEX			SUMMIT EAFE INTERNATIONAL INDEX F CLASS		SUMMIT NASDAQ 100 INDEX			SUMMIT RUSSELL 2000 SMALL CAP INDEX F CLASS
Contract Maintenance Charges
Spinnaker & Mainsail	$	(30	)	$	(7,388	)	$	-	$	(30	)	$	-
Spinnaker Advisor		-			-			-		-			-
Spinnaker with EEB		-			-			-		-			-
Spinnaker with GMDB		-			-			-		-			-
Spinnaker with EEB & GMDB		-			-			-		-			-
Spinnaker Choice		-			-			-		-			-
Spinnaker Choice with EEB		-			-			-		-			-
Spinnaker Choice with GMDB		-			-			-		-			-
Spinnaker Choice with EEB & GMDB		-			-			-		-			-
Focus Tier I		-			-			-		-			-
Focus Tier II		-			-			-		-			-
Focus Tier III		-			-			-		-			-
Focus Tier IV		-			-			-		-			-
Focus Tier V		-			-			-		-			-
Focus Tier I with GMDB		-			-			-		-			-
Focus Tier II with GMDB		-			-			-		-			-
Focus Tier III with GMDB		-			-			-		-			-
Focus Tier IV with GMDB		-			-			-		-			-
Focus Tier V with GMDB		-			-			-		-			-
Increase (Decrease) from Contract Transactions		49,900			811,999			81,643		54,950			433,569
Total Increase (Decrease) in Net Assets		61,843			831,830			85,234		77,804			616,131
Net Assets at December 31, 2009	$	64,254		$	1,121,129		$	85,371	$	86,220		$	787,762

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
106

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	SUMMIT S&P MID CAP 400 INDEX F CLASS			TEMPLETON DEVELOPING MARKETS II			TEMPLETON GLOBAL BOND SECURITIES II1			TEMPLETON GROWTH SECURITIES II			VANGUARD BALANCED
Net Assets at January 1, 2008	$	-		$	7,900,298		$	2,293,293		$	7,550,675		$	252,256
Increase in Net Assets from Operations
Net Investment Income (Loss)		21			68,725			72,255			21,818			2,885
Realized Gains (Losses)		(16	)		1,425,304			119,153			460,980			4,361
Net Change in Unrealized Appreciation (Depreciation)		(4,946	)		(5,366,370	)		(59,396	)		(3,767,556	)		(147,126	)
Net Increase (Decrease) in Net Assets Resulting from Operations		(4,941	)		(3,872,341	)		132,012			(3,284,758	)		(139,880	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		17,507			906,486			2,639,657			1,250,093			-
Spinnaker Advisor		-			137,111			407,325			37,345			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			854			72,507			14,117			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			585			17			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			78,831
Focus Tier II		-			-			-			-			5,748
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			2,883
Focus Tier II with GMDB		-			-			-			-			368,655
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		-			(945,335	)		(818,035	)		(1,054,807	)		-
Spinnaker Advisor		-			(703,123	)		(618,025	)		(51,784	)		-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			(12	)		-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			(213,863	)		(59,432	)		(17,706	)		-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			(30	)		(3	)		-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			(15,208	)
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			(2,080	)
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
107

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	SUMMIT S&P MID CAP 400 INDEX F CLASS		TEMPLETON DEVELOPING MARKETS II			TEMPLETON GLOBAL BOND SECURITIES II1			TEMPLETON GROWTH SECURITIES II			VANGUARD BALANCED
Contract Maintenance Charges
Spinnaker & Mainsail	$	-	$	(462	)	$	(8,787	)	$	(1,065	)	$	-
Spinnaker Advisor		-		-			-			-			-
Spinnaker with EEB		-		-			-			-			-
Spinnaker with GMDB		-		-			-			-			-
Spinnaker with EEB & GMDB		-		-			-			-			-
Spinnaker Choice		-		-			-			-			-
Spinnaker Choice with EEB		-		-			-			-			-
Spinnaker Choice with GMDB		-		-			-			-			-
Spinnaker Choice with EEB & GMDB		-		-			-			-			-
Focus Tier I		-		-			-			-			(40	)
Focus Tier II		-		-			-			-			-
Focus Tier III		-		-			-			-			-
Focus Tier IV		-		-			-			-			-
Focus Tier V		-		-			-			-			-
Focus Tier I with GMDB		-		-			-			-			-
Focus Tier II with GMDB		-		-			-			-			-
Focus Tier III with GMDB		-		-			-			-			-
Focus Tier IV with GMDB		-		-			-			-			-
Focus Tier V with GMDB		-		-			-			-			-
Increase (Decrease) from Contract Transactions		17,507		(817,777	)		1,615,212			176,193			438,789
Total Increase (Decrease) in Net Assets		12,566		(4,690,118	)		1,747,224			(3,108,565	)		298,909
Net Assets at December 31, 2008	$	12,566	$	3,210,180		$	4,040,517		$	4,442,110		$	551,165

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
108

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	SUMMIT S&P MID CAP 400 INDEX F CLASS			TEMPLETON DEVELOPING MARKETS II			TEMPLETON GLOBAL BOND SECURITIES II1			TEMPLETON GROWTH SECURITIES II			VANGUARD BALANCED
Net Assets at December 31, 2008	$	12,566		$	3,210,180		$	4,040,517		$	4,442,110		$	551,165
Increase in Net Assets from Operations
Net Investment Income (Loss)		(1,244	)		111,746			571,369			86,973			17,282
Realized Gains (Losses)		31,861			(586,831	)		21,127			(269,322	)		(9,136	)
Net Change in Unrealized Appreciation (Depreciation)		20,295			2,759,140			128,745			1,523,360			119,747
Net Increase (Decrease) in Net Assets Resulting from Operations		50,912			2,284,055			721,241			1,341,011			127,893
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		133,361			760,158			1,847,544			844,750			-
Spinnaker Advisor		-			154,568			397,223			11,752			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			372			2,334			321			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			69			17			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			32,449
Focus Tier II		-			-			-			-			17,997
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			7
Focus Tier II with GMDB		-			-			-			-			13,080
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			74,357
Contract Terminations, Transfers Out
Spinnaker & Mainsail		(121,021	)		(740,240	)		(757,498	)		(620,242	)		-
Spinnaker Advisor		-			(150,588	)		(88,365	)		(34,851	)		-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			(1,479	)		-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			(13,157	)		(7,666	)		(9,843	)		-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			(579	)		(30	)		-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		-			-			-			-			(3,614	)
Focus Tier II		-			-			-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			(40	)
Focus Tier II with GMDB		-			-			-			-			(24,482	)
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			(129	)

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
109

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	SUMMIT S&P MID CAP 400 INDEX F CLASS		TEMPLETON DEVELOPING MARKETS II			TEMPLETON GLOBAL BOND SECURITIES II1			TEMPLETON GROWTH SECURITIES II			VANGUARD BALANCED
Contract Maintenance Charges
Spinnaker & Mainsail	$	-	$	(541	)	$	(10,119	)	$	(1,074	)	$	-
Spinnaker Advisor		-		-			-			-			-
Spinnaker with EEB		-		-			-			-			-
Spinnaker with GMDB		-		-			-			-			-
Spinnaker with EEB & GMDB		-		-			-			-			-
Spinnaker Choice		-		-			-			-			-
Spinnaker Choice with EEB		-		-			-			-			-
Spinnaker Choice with GMDB		-		-			-			-			-
Spinnaker Choice with EEB & GMDB		-		-			-			-			-
Focus Tier I		-		-			-			-			-
Focus Tier II		-		-			-			-			-
Focus Tier III		-		-			-			-			-
Focus Tier IV		-		-			-			-			-
Focus Tier V		-		-			-			-			-
Focus Tier I with GMDB		-		-			-			-			-
Focus Tier II with GMDB		-		-			-			-			-
Focus Tier III with GMDB		-		-			-			-			-
Focus Tier IV with GMDB		-		-			-			-			-
Focus Tier V with GMDB		-		-			-			-			-
Increase (Decrease) from Contract Transactions		12,340		10,062			1,381,961			190,813			109,625
Total Increase (Decrease) in Net Assets		63,252		2,294,117			2,103,202			1,531,824			237,518
Net Assets at December 31, 2009	$	75,818	$	5,504,297		$	6,143,719		$	5,973,934		$	788,683

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
110

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	VANGUARD HIGH YIELD BOND			VANGUARD INTERNATIONAL			VANGUARD MID-CAP INDEX			VANGUARD REIT INDEX			VANGUARD TOTAL BOND MARKET INDEX
Net Assets at January 1, 2008	$	259,748		$	237,696		$	690,668		$	126,934		$	991,506
Increase in Net Assets from Operations
Net Investment Income (Loss)		21,581			1,155			(319	)		2,566			35,272
Realized Gains (Losses)		(16,078	)		(25,574	)		21,737			17,529			(5,380	)
Net Change in Unrealized Appreciation (Depreciation)		(137,324	)		(258,030	)		(601,052	)		(156,994	)		68,146
Net Increase (Decrease) in Net Assets Resulting from Operations		(131,821	)		(282,449	)		(579,634	)		(136,899	)		98,038
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		-			-			-			-			-
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		153,294			393,580			458,668			140,746			513,906
Focus Tier II		228,664			270,516			567,601			197,586			1,134,600
Focus Tier III		29,136			64,661			77,031			25,234			302,069
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		20,408			40,073			79,644			11,338			97,649
Focus Tier II with GMDB		27,979			19,431			52,121			5,948			68,544
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		-			-			-			-			-
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		(18,392	)		(124,916	)		(95,372	)		(18,187	)		(88,427	)
Focus Tier II		(22,570	)		(64,062	)		(79,211	)		(36,329	)		(164,148	)
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
111

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	VANGUARD HIGH YIELD BOND			VANGUARD INTERNATIONAL			VANGUARD MID-CAP INDEX			VANGUARD REIT INDEX			VANGUARD TOTAL BOND MARKET INDEX
Contract Maintenance Charges
Spinnaker & Mainsail	$	-		$	-		$	-		$	-		$	-
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		(4	)		(362	)		(6	)		(1	)		(18	)
Focus Tier II		-			(80	)		-			-			-
Focus Tier III		-			-			-			-			-
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		-			-			-			-			-
Focus Tier II with GMDB		-			-			-			-			-
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			-			-			-			-
Increase (Decrease) from Contract Transactions		418,515			598,841			1,060,476			326,335			1,864,175
Total Increase (Decrease) in Net Assets		286,694			316,392			480,842			189,436			1,962,213
Net Assets at December 31, 2008	$	546,442		$	554,088		$	1,171,510		$	316,370		$	2,953,719

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
112

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	VANGUARD HIGH YIELD BOND			VANGUARD INTERNATIONAL			VANGUARD MID-CAP INDEX			VANGUARD REIT INDEX			VANGUARD TOTAL BOND MARKET INDEX
Net Assets at December 31, 2008	$	546,442		$	554,088		$	1,171,510		$	316,370		$	2,953,719
Increase in Net Assets from Operations
Net Investment Income (Loss)		44,332			18,754			6,070			12,780			84,889
Realized Gains (Losses)		(31,527	)		(69,624	)		(257,654	)		(103,652	)		6,227
Net Change in Unrealized Appreciation (Depreciation)		198,442			380,138			754,430			202,151			42,355
Net Increase (Decrease) in Net Assets Resulting from Operations		211,247			329,268			502,846			111,279			133,471
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		-			-			-			-			-
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		61,259			85,314			159,675			47,283			267,716
Focus Tier II		35,875			174,717			176,132			59,476			230,685
Focus Tier III		96,989			112,330			135,833			24,855			282,929
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		24,169			11,862			38,995			3,423			106,562
Focus Tier II with GMDB		10,312			33,945			14,399			14,399			229,227
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		-			72,849			-			-			412,440
Contract Terminations, Transfers Out
Spinnaker & Mainsail		-			-			-			-			-
Spinnaker Advisor		-			-			-			-			-
Spinnaker with EEB		-			-			-			-			-
Spinnaker with GMDB		-			-			-			-			-
Spinnaker with EEB & GMDB		-			-			-			-			-
Spinnaker Choice		-			-			-			-			-
Spinnaker Choice with EEB		-			-			-			-			-
Spinnaker Choice with GMDB		-			-			-			-			-
Spinnaker Choice with EEB & GMDB		-			-			-			-			-
Focus Tier I		(33,287	)		(58,230	)		(93,809	)		(39,327	)		(109,483	)
Focus Tier II		(62,595	)		(36,991	)		(87,846	)		(26,173	)		(313,429	)
Focus Tier III		(4,308	)		(6,937	)		(7,909	)		(1,742	)		(156,454	)
Focus Tier IV		-			-			-			-			-
Focus Tier V		-			-			-			-			-
Focus Tier I with GMDB		(774	)		(873	)		(1,144	)		-			(678	)
Focus Tier II with GMDB		(24,438	)		(11,796	)		(34,330	)		(2,959	)		(66,890	)
Focus Tier III with GMDB		-			-			-			-			-
Focus Tier IV with GMDB		-			-			-			-			-
Focus Tier V with GMDB		(24,107	)		(3,722	)		(295,732	)		(63,674	)		-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
113

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	VANGUARD HIGH YIELD BOND		VANGUARD INTERNATIONAL			VANGUARD MID-CAP INDEX			VANGUARD REIT INDEX		VANGUARD TOTAL BOND MARKET INDEX
Contract Maintenance Charges
Spinnaker & Mainsail	$	-	$	-		$	-		$	-	$	-
Spinnaker Advisor		-		-			-			-		-
Spinnaker with EEB		-		-			-			-		-
Spinnaker with GMDB		-		-			-			-		-
Spinnaker with EEB & GMDB		-		-			-			-		-
Spinnaker Choice		-		-			-			-		-
Spinnaker Choice with EEB		-		-			-			-		-
Spinnaker Choice with GMDB		-		-			-			-		-
Spinnaker Choice with EEB & GMDB		-		-			-			-		-
Focus Tier I		-		(1,172	)		(8	)		-		-
Focus Tier II		-		-			-			-		-
Focus Tier III		-		-			-			-		-
Focus Tier IV		-		-			-			-		-
Focus Tier V		-		-			-			-		-
Focus Tier I with GMDB		-		(40	)		-			-		-
Focus Tier II with GMDB		-		-			-			-		-
Focus Tier III with GMDB		-		-			-			-		-
Focus Tier IV with GMDB		-		-			-			-		-
Focus Tier V with GMDB		-		-			-			-		-
Increase (Decrease) from Contract Transactions		79,095		371,256			4,256			15,561		882,625
Total Increase (Decrease) in Net Assets		290,342		700,524			507,102			126,840		1,016,096
Net Assets at December 31, 2009	$	836,784	$	1,254,612		$	1,678,612		$	443,210	$	3,969,815

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
114

Symetra Separate Account C

Statements of Changes in Net Assets

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	VANGUARD TOTAL STOCK MARKET INDEX			WANGER USA
Net Assets at January 1, 2008	$	878,339		$	516,406
Increase in Net Assets from Operations
Net Investment Income (Loss)		(2,128	)		(5,820	)
Realized Gains (Losses)		(39,130	)		62,524
Net Change in Unrealized Appreciation (Depreciation)		(639,474	)		(258,779	)
Net Increase (Decrease) in Net Assets Resulting from Operations		(680,732	)		(202,075	)
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		-			13,065
Spinnaker Advisor		-			-
Spinnaker with EEB		-			-
Spinnaker with GMDB		-			-
Spinnaker with EEB & GMDB		-			-
Spinnaker Choice		-			-
Spinnaker Choice with EEB		-			-
Spinnaker Choice with GMDB		-			-
Spinnaker Choice with EEB & GMDB		-			-
Focus Tier I		615,949			-
Focus Tier II		869,613			-
Focus Tier III		156,550			-
Focus Tier IV		-			-
Focus Tier V		-			-
Focus Tier I with GMDB		96,070			-
Focus Tier II with GMDB		59,469			-
Focus Tier III with GMDB		-			-
Focus Tier IV with GMDB		-			-
Focus Tier V with GMDB		-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		-			(44,462	)
Spinnaker Advisor		-			-
Spinnaker with EEB		-			-
Spinnaker with GMDB		-			-
Spinnaker with EEB & GMDB		-			-
Spinnaker Choice		-			-
Spinnaker Choice with EEB		-			-
Spinnaker Choice with GMDB		-			-
Spinnaker Choice with EEB & GMDB		-			-
Focus Tier I		(95,394	)		-
Focus Tier II		(108,244	)		-
Focus Tier III		-			-
Focus Tier IV		-			-
Focus Tier V		-			-
Focus Tier I with GMDB		-			-
Focus Tier II with GMDB		-			-
Focus Tier III with GMDB		-			-
Focus Tier IV with GMDB		-			-
Focus Tier V with GMDB

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
115

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	VANGUARD TOTAL STOCK MARKET INDEX			WANGER USA
Contract Maintenance Charges
Spinnaker & Mainsail	$	-		$	(450	)
Spinnaker Advisor		-			-
Spinnaker with EEB		-			-
Spinnaker with GMDB		-			-
Spinnaker with EEB & GMDB		-			-
Spinnaker Choice		-			-
Spinnaker Choice with EEB		-			-
Spinnaker Choice with GMDB		-			-
Spinnaker Choice with EEB & GMDB		-			-
Focus Tier I		(89	)		-
Focus Tier II		-			-
Focus Tier III		-			-
Focus Tier IV		-			-
Focus Tier V		-			-
Focus Tier I with GMDB		-			-
Focus Tier II with GMDB		-			-
Focus Tier III with GMDB		-			-
Focus Tier IV with GMDB		-			-
Focus Tier V with GMDB		-			-
Increase (Decrease) from Contract Transactions		1,593,924			(31,847	)
Total Increase (Decrease) in Net Assets		913,192			(233,922	)
Net Assets at December 31, 2008	$	1,791,531		$	282,484

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
116

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	VANGUARD TOTAL STOCK MARKET INDEX			WANGER USA
Net Assets at December 31, 2008	$	1,791,531		$	282,484
Increase in Net Assets from Operations
Net Investment Income (Loss)		14,082			(4,172	)
Realized Gains (Losses)		(264,411	)		10,413
Net Change in Unrealized Appreciation (Depreciation)		833,235			102,366
Net Increase (Decrease) in Net Assets Resulting from Operations		582,906			108,607
Contract Transactions
Contract Purchase Payments and Transfers In
Spinnaker & Mainsail		-			2,520
Spinnaker Advisor		-			-
Spinnaker with EEB		-			-
Spinnaker with GMDB		-			-
Spinnaker with EEB & GMDB		-			-
Spinnaker Choice		-			-
Spinnaker Choice with EEB		-			-
Spinnaker Choice with GMDB		-			-
Spinnaker Choice with EEB & GMDB		-			-
Focus Tier I		243,195			-
Focus Tier II		325,460			-
Focus Tier III		159,734			-
Focus Tier IV		-			-
Focus Tier V		-			-
Focus Tier I with GMDB		80,096			-
Focus Tier II with GMDB		109,779			-
Focus Tier III with GMDB		-			-
Focus Tier IV with GMDB		-			-
Focus Tier V with GMDB		-			-
Contract Terminations, Transfers Out
Spinnaker & Mainsail		-			(68,090	)
Spinnaker Advisor		-			-
Spinnaker with EEB		-			-
Spinnaker with GMDB		-			-
Spinnaker with EEB & GMDB		-			-
Spinnaker Choice		-			-
Spinnaker Choice with EEB		-			-
Spinnaker Choice with GMDB		-			-
Spinnaker Choice with EEB & GMDB		-			-
Focus Tier I		(171,478	)		-
Focus Tier II		(117,632	)		-
Focus Tier III		(9,857	)		-
Focus Tier IV		-			-
Focus Tier V		-			-
Focus Tier I with GMDB		(601	)		-
Focus Tier II with GMDB		(39,581	)		-
Focus Tier III with GMDB		-			-
Focus Tier IV with GMDB		-			-
Focus Tier V with GMDB		(366,181	)		-

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
117

Symetra Separate Account C

Statements of Changes in Net Assets (continued)

Year Ended December 31, 2008 and 2009

	Sub-Accounts
	VANGUARD TOTAL STOCK MARKET INDEX			WANGER USA
Contract Maintenance Charges
Spinnaker & Mainsail	$	-		$	(330	)
Spinnaker Advisor		-			-
Spinnaker with EEB		-			-
Spinnaker with GMDB		-			-
Spinnaker with EEB & GMDB		-			-
Spinnaker Choice		-			-
Spinnaker Choice with EEB		-			-
Spinnaker Choice with GMDB		-			-
Spinnaker Choice with EEB & GMDB		-			-
Focus Tier I		(120	)		-
Focus Tier II		-			-
Focus Tier III		-			-
Focus Tier IV		-			-
Focus Tier V		-			-
Focus Tier I with GMDB		-			-
Focus Tier II with GMDB		-			-
Focus Tier III with GMDB		-			-
Focus Tier IV with GMDB		-			-
Focus Tier V with GMDB		-			-
Increase (Decrease) from Contract Transactions		212,814			(65,900	)
Total Increase (Decrease) in Net Assets		795,720			42,707
Net Assets at December 31, 2009	$	2,587,251		$	325,191

¹  Reference Note 1 for name changes, reorganizations and commencement dates

SEE NOTES TO FINANCIAL STATEMENTS
118

Symetra Separate Account C

Notes to Financial Statements

1.  ORGANIZATION

Symetra Separate Account C ("the Separate Account") is registered under the Investment Company Act of 1940, as amended, as a segregated unit investment trust of Symetra Life Insurance Company ("Symetra Life"), a wholly-owned subsidiary of Symetra Financial Corporation. Purchasers of various Symetra Life variable annuity products direct their investment to one or more of the sub-accounts of the Separate Account through the purchase of accumulation units ("Units"). Under the terms of the registration, the Separate Account is authorized to issue an unlimited number of Units. Each sub-account invests in shares of a designated portfolio of an open-ended registered investment company ("Mutual Fund") as indicated below. Not all sub-accounts are available in all Symetra Life variable annuity products. The performance of the underlying portfolios may differ substantially from publicly traded mutual funds with similar names and objectives.

Sub-Account	Mutual Fund
	AIM Variable Insurance Funds, Inc
AIM Capital Appreciation I	AIM V.I. Capital Appreciation Fund (Series I shares)
AIM Capital Appreciation II	AIM V.I. Capital Appreciation Fund (Series II shares)
AIM Capital Development Series I	AIM V.I. Capital Development Fund (Series I shares)
AIM Capital Development Series II	AIM V.I. Capital Development Fund (Series II shares)
AIM Global Healthcare	AIM V.I. Global Health Care Fund (Series I shares)
AIM Global Real Estate	AIM V.I. Global Real Estate Fund (Series I shares)
AIM International Growth I	AIM V.I. International Growth Fund (Series I shares)
AIM International Growth II	AIM V.I. International Growth Fund (Series II shares)
AIM Mid Cap Core Equity II2	AIM V.I. Mid Cap Core Equity Fund (Series II shares)
AIM Small Cap Equity II	AIM V.I. Small Cap Equity Fund (Series II shares)
	American Century Variable Portfolios, Inc.
American Century Balanced	VP Balanced Fund
American Century Inflation Protection II	VP Inflation Protection Class II Fund
American Century International	VP International Fund
American Century International II2	VP International Class II Fund
American Century Large Company Value II	VP Large Company Value Class II Fund
American Century Ultra I	VP Ultra Class I Fund
American Century Ultra II	VP Ultra Class II Fund
American Century Value	VP Value Fund
	BlackRock Variable Series Fund, Inc.
BlackRock Global Allocation III2	BlackRock Global Allocation V.I. Fund, Class III
BlackRock Global Growth III2	BlackRock Global Growth V.I. Fund, Class III
BlackRock Large Cap Value III2	BlackRock Large Cap Value V.I. Fund, Class III
	Calvert Variable Series, Inc.
Calvert Social Balanced2	Calvert Social Balanced Portfolio
Calvert Social Equity2	Calvert Social Equity Portfolio
Calvert Social Mid-Cap Growth2	Calvert Social Mid-Cap Growth Portfolio
	Columbia Funds Variable Insurance Trust
Columbia Mid-Cap Value B2	Columbia Mid Cap Value Fund, Variable Series Class B Shares
Columbia Mid-Cap Growth B2	Columbia Mid-Cap Growth Fund, Variable Series Class B Shares
Columbia Small Company Growth B2	Columbia Small Company Growth Fund, Variable Series Class B Shares
Columbia Small Cap Value B2	Columbia Small Cap Value Fund, Variable Series Class B Shares
	Dreyfus Variable Investment Fund
Dreyfus Appreciation	Dreyfus VIF Capital Portfolio — Initial Shares
Dreyfus Quality Bond	Dreyfus VIF Quality Bond Portfolio — Initial Shares

119

Symetra Separate Account C

Notes to Financial Statements

1.  ORGANIZATION (Continued)

Sub-Account	Mutual Fund
	Dreyfus Investment Portfolios
Dreyfus MidCap Stock	Dreyfus IP MidCap Stock Portfolio — Initial Shares
Dreyfus Technology Growth	Dreyfus IP Technology Growth Portfolio — Initial Shares
	Dreyfus Socially Responsible Growth Fund, Inc.
Dreyfus Socially Responsible	Dreyfus Socially Responsible Growth Fund, Inc. — Initial Shares
	Dreyfus Stock Index Fund, Inc.
Dreyfus Stock Index	Dreyfus Stock Index Fund, Inc. — Service Shares
	DWS Variable Series I and II
DWS Balanced VIP A	DWS Balanced VIP (A)
DWS Capital Growth VIP B	DWS Capital Growth VIP — Class B Shares
DWS Dreman Small Mid Cap Value B2	DWS Dreman Small Mid Cap Value Fund — Class B Shares
DWS Global Opportunities B Share	DWS Global Opportunities VIP — Class B Shares
DWS Global Thematic B Share	DWS Global Thematic VIP — Class B Shares
DWS International VIP A	DWS International VIP — Class A Shares
	DWS Investments VIT Funds
DWS Small Cap Index A Share	DWS Small Cap Index VIP — Class A Shares
	Federated Insurance Series
Federated Capital Income	Federated Capital Income Fund II
Federated High Income Bond	Federated High Income Bond Fund II
Federated International Equity	Federated International Equity Fund II
	Fidelity Variable Insurance Products Fund 1 (VIP)
Fidelity Asset Manager	VIP Asset Manager Portfolio — Initial Class
Fidelity Contrafund	VIP Contrafund® Portfolio — Initial Class
Fidelity Contrafund II2	VIP Contrafund® Portfolio — Service Class 2
Fidelity Equity Income	VIP Equity-Income Portfolio — Initial Class
Fidelity Freedom Funds 2010 II	VIP Freedom Funds 2010 Portfolio — Service Class 2
Fidelity Freedom Funds 2015 II	VIP Freedom Funds 2015 Portfolio — Service Class 2
Fidelity Freedom Funds 2020 II	VIP Freedom Funds 2020 Portfolio — Service Class 2
Fidelity Freedom Funds 2025 II	VIP Freedom Funds 2025 Portfolio — Service Class 2
Fidelity Freedom Funds 2030 II	VIP Freedom Funds 2030 Portfolio — Service Class 2
Fidelity Freedom Funds 2035 II2	VIP Freedom 2035 Portfolio — Service Class 2
Fidelity Freedom Funds 2040 II2	VIP Freedom 2040 Portfolio — Service Class 2
Fidelity Freedom Funds 2045 II2	VIP Freedom 2045 Portfolio — Service Class 2
Fidelity Freedom Funds 2050 II2	VIP Freedom 2050 Portfolio — Service Class 2
Fidelity Freedom Income Fund II	VIP Freedom Income Portfolio — Service Class 2
Fidelity Growth	VIP Growth Portfolio — Initial Class
Fidelity Growth & Income	VIP Growth & Income Portfolio — Initial Class
Fidelity Growth Opportunities	VIP Growth Opportunities Portfolio — Initial Class
Fidelity Index 500	VIP Index 500 Portfolio — Initial Class
Fidelity Mid-Cap Advisor II	VIP Mid Cap Portfolio — Service Class II
Fidelity Money Market Fund	VIP Money Market Portfolio — Initial Class
Fidelity Overseas II	VIP Overseas Portfolio — Service Class 2
Fidelity VIP Money Market Service Class	VIP Money Market Portfolio — Service Class II

120

Symetra Separate Account C

Notes to Financial Statements

1.  ORGANIZATION (Continued)

Sub-Account	Mutual Fund
	Financial Investors Variable Insurance Trust
Ibbotson Aggressive Growth Class I	Ibbotson Aggressive Growth ETF Asset Allocation Portfolio —
	Class I
Ibbotson Aggressive Growth Class II	Ibbotson Aggressive Growth ETF Asset Alloc. Portfolio — Class II
Ibbotson Balanced Class I	Ibbotson Balanced ETF Asset Allocation Portfolio — Class I
Ibbotson Balanced Class II	Ibbotson Balanced ETF Asset Allocation Portfolio — Class II
Ibbotson Conservative Class I	Ibbotson Conservative ETF Asset Allocation Portfolio — Class I
Ibbotson Conservative Class II	Ibbotson Conservative ETF Asset Allocation Portfolio — Class II
Ibbotson Growth Class I	Ibbotson Growth ETF Asset Allocation Portfolio — Class I
Ibbotson Growth Class II	Ibbotson Growth ETF Asset Allocation Portfolio — Class II
Ibbotson Income and Growth Class I	Ibbotson Income and Growth ETF Asset Allocation Portfolio —
	Class I
Ibbotson Income and Growth Class II	Ibbotson Income and Growth ETF Asset Allocation Portfolio —
	Class II
	Franklin Templeton Variable Insurance Products Trust
Franklin Flex Cap Growth Securities	Franklin Flex Cap Growth Securities Fund — Class 2
Franklin Founding Allocation Fund Class II	Franklin Templeton VIP Founding Funds Allocation Fund — Class 2
Franklin Income Securities Fund Class II	Franklin Income Securities Fund — Class 2
Franklin Small Cap Value Fund II	Franklin Small Cap Value Securities Fund — Class 2
Franklin Small-Mid Cap Growth II	Franklin Small-Mid Cap Growth Securities Fund — Class 2
Franklin U.S. Government II	Franklin U.S. Government Securities Fund — Class 2
	ING Investors Trust
ING JP Morgan Emerging Markets Equity I	ING JP Morgan Emerging Markets Equity Portfolio
	ING VP Natural Resource Trust
ING Global Resources	ING VP Natural Resources Portfolio
	Goldman Sachs Variable Insurance Trust (VIT)
Goldman Sachs Government Income2	Goldman Sachs VIT Government Income Fund — Service Shares
	JP Morgan Insurance Trust
JP Morgan Insurance Trust International Equity I4	JP Morgan Insurance Trust International Equity Portfolio
JP Morgan Insurance Trust Mid-Cap Value I5	JP Morgan Insurance Trust Mid Cap Value Portfolio
JP Morgan Insurance Trust U.S. Equity I6	JP Morgan Insurance Trust U.S. Equity Portfolio
	JP Morgan Series Trust II
JP Morgan International Equity4	JP Morgan International Equity Portfolio
JP Morgan Mid-Cap Value5	JP Morgan Mid Cap Value Portfolio
JP Morgan U.S. Large Cap Core Equity6	JP Morgan U.S. Large Cap Core Equity Portfolio
	Franklin Templeton Variable Insurance Products Trust
Mutual Shares Securities	Mutual Shares Securities Fund — Class 2
	Neuberger Berman Advisers Management Trust
Neuberger Berman AMT Guardian Class S	Neuberger Berman AMT Guardian Portfolio — Class S
Neuberger Berman AMT Mid Cap Growth Class S	Neuberger Berman AMT Mid Cap Growth Portfolio — Class S
Neuberger Berman AMT Regency Class S	Neuberger Berman AMT Regency Portfolio — Class S
	PIMCO Variable Insurance Trust
PIMCO All Asset Portfolio Advisor	PIMCO All Asset Portfolio — Advisor Class Shares
PIMCO Commodity Fund Admin	PIMCO Commodity Real Return Strategy Portfolio —
	Administrative Class Shares
PIMCO Total Return Portfolio Advisor2	PIMCO Total Return Portfolio — Advisor Class Shares

121

Symetra Separate Account C

Notes to Financial Statements

1.  ORGANIZATION (Continued)

Sub-Account	Mutual Fund
	Pioneer Variable Contracts Trust
Pioneer Bond VCT Class I	Pioneer Bond VCT Portfolio — Class I
Pioneer Emerging Markets VCT Class II	Pioneer Emerging Markets VCT Portfolio — Class II
Pioneer Equity Income VCT Class II	Pioneer Equity Income VCT Portfolio — Class II
Pioneer Fund VCT Class I	Pioneer Fund VCT Portfolio — Class I
Pioneer Growth Opportunities VCT Class I	Pioneer Growth Opportunities VCT Portfolio — Class I
Pioneer High Yield VCT Class II	Pioneer High Yield VCT Portfolio — Class II
Pioneer Mid-Cap Value VCT Class I	Pioneer Mid Cap Value VCT Portfolio — Class I
Pioneer Money Market VCT Class I	Pioneer Money Market VCT Portfolio — Class I
Pioneer Real Estate VCT Class II	Pioneer Real Estate VCT Portfolio — Class II
Pioneer Small-Cap Value VCT Class I1	Pioneer Small Cap Value VCT Portfolio — Class I
Pioneer Small-Cap Value VCT Class II1	Pioneer Small Cap Value VCT Portfolio — Class II
Pioneer Strategic Income VCT Class II	Pioneer Strategic Income VCT Portfolio — Class II
	Summit Mutual Funds, Inc.
Summit Balance Index	Summit Balanced Index Portfolio
Summit Barclays Aggregate Bond Index	Summit Barclays Capital Aggregate Bond Index Portfolio
Summit EAFE International Index F Class	Summit EAFE International Index Portfolio — Class F
Summit Nasdaq 100 Index	Summit Nasdaq — 100 Index Portfolio
Summit Russell 2000 Small Cap Index F Class	Summit Russell 2000 Small Cap Index Portfolio — Class F
Summit S&P Midcap 400 Index F Class	Summit S&P MidCap 400 Index Portfolio — Class F
	Franklin Templeton Variable Insurance Products Trust
Templeton Developing Markets II	Templeton Developing Markets Securities Fund — Class 2
Templeton Global Bond Securities II3	Templeton Global Bond Securities Fund — Class 2
Templeton Growth Securities II	Templeton Growth Securities Fund — Class 2
	Vanguard Variable Insurance Fund Portfolios
Vanguard Balanced	Vanguard VIF — Balanced Portfolio
Vanguard High Yield Bond	Vanguard VIF — High Yield Bond Portfolio
Vanguard International	Vanguard VIF — International Portfolio
Vanguard Mid-Cap Index	Vanguard VIF — Mid-Cap Index Portfolio
Vanguard REIT Index	Vanguard VIF — REIT Index Portfolio
Vanguard Total Bond Market Index	Vanguard VIF — Total Bond Market Index Portfolio
Vanguard Total Stock Market Index	Vanguard VIF — Total Stock Market Index Portfolio
	Wanger Advisors Trust
Wanger USA	Wanger USA
Retail Funds available to the public outside of variable annuity contracts:
	American Funds (R4 Shares)
American Funds AMCAP2	American Funds AMCAP Fund
American Funds American Balanced2	American Funds American Balanced Fund
American Funds American High-Income Trust2	American Funds American High-Income Trust Fund
American Funds Capital World Bond2	American Funds Capital World Bond Fund
American Funds EuroPacific Growth2	American Funds EuroPacific Growth Fund
American Funds The Growth Fund of America2	American Funds The Growth Fund of America
American Funds The Investment Company of America2	American Funds The Investment Company of America
American Funds New Perspective2	American Funds New Perspective Fund
American Funds Washington Mutual Investors2	American Funds Washington Mutual Investors Fund

122

Symetra Separate Account C

Notes to Financial Statements

1.  ORGANIZATION (Continued)

Sub-Account	Mutual Fund
	Neuberger Berman Advisers Management Trust
Neuberger Berman Genesis Advisor2	Neuberger Berman Genesis Fund — Advisor Class

  ¹  Pioneer Small-Cap Value VCT Class I and Pioneer Small-Cap Value VCT Class II liquidated April 24, 2009.

  ²  The commencement date was December 7, 2009. However, there has been no activity to report in 2009.

  ³  Templeton Global Bond Securities II was known as Templeton Global Income Securities II prior to May 1, 2009.

  ⁴  JP Morgan International Equity merged into JP Morgan Insurance Trust International Equity I April 27, 2009.

  ⁵  JP Morgan Mid-Cap Value merged into JP Morgan Insurance Trust Mid Cap Value I April 27, 2009.

  ⁶  JP Morgan U.S. Large Cap Core Equity merged into JP Morgan Insurance Trust U.S. Equity I April 27, 2009.

Under applicable insurance law, the assets of the Separate Account are legally segregated and are not subject to claims that arise out of Symetra Life's other business activities.

2.  SIGNIFICANT ACCOUNTING POLICIES

BASIS OF PRESENTATION AND USE OF ESTIMATES — The financial statements have been prepared in conformity with U.S. generally accepted accounting principles (GAAP), including the rules and regulations of the Securities and Exchange Commission (SEC). The preparation of the Separate Account financial statements in conformity with GAAP requires the Separate Account to make estimates and assumptions that may affect the amounts reported in the audited financial statements and accompanying notes.

INVESTMENT VALUATION — Investments in portfolio shares are valued at fair value based on the net asset value (NAV) as reported by the underlying portfolio on the last trading day of the year.

The Separate Account determines the fair value of its financial instruments based on the fair value hierarchy, which requires an entity to maximize its use of observable inputs and minimize the use of unobservable inputs when measuring fair value. This fair value hierarchy prioritizes fair value measurements into the three levels based on the nature of the inputs. Quoted prices in active markets for identical assets or liabilities have the highest priority ("Level 1"), followed by observable inputs other than quoted market prices, including prices for similar but not identical assets or liabilities ("Level 2") and unobservable inputs, including the reporting entity's estimates of the assumptions that market participants would use, having the lowest priority ("Level 3").

The availability of observable market information is the principal factor in determining the level to which the Separate Account's investments are assigned in the fair value hierarchy. As such, all Separate Account investments have been classified as Level 1 in the fair value hierarchy.

INVESTMENT TRANSACTIONS — Investment transactions are recorded on the trade date. Realized gains and losses on investment transactions are determined using the first-in-first-out (FIFO) method.

INCOME RECOGNITION — Dividend income and realized capital gain distributions received are recorded on the ex-dividend date.

DISTRIBUTIONS — The net investment income and realized capital gains of the Separate Account are not distributed, but are retained and reinvested for the benefit of unit owners.

FEDERAL INCOME TAX — Operations of the Separate Account are included in the federal income tax return of Symetra Life, which is taxed as a "Life Insurance Company" under the provisions of the Internal Revenue Code. Under current federal income tax law, no income taxes are payable with respect to operations of the Separate Account to the extent the earnings are reinvested.

ADOPTION OF NEW ACCOUNTING PRONOUNCEMENTS — The Separate Account has adopted Statement of Financial Accounting Standard (SFAS) No. 168 (ASC 105-10), FASB Accounting Standards Codification and the Hierarchy of Generally Accepted Accounting Principles, which established the FASB Accounting Standards Codification (Codification or ASC) as the single source of authoritative GAAP. GAAP is not intended to be changed as a result of the FASB's Codification project, but it does change the way the guidance is organized and presented.

123

Symetra Separate Account C

Notes to Financial Statements

3.  EXPENSES AND RELATED PARTY TRANSACTIONS

Symetra Life assumes mortality and expense ("M&E") risks and incurs asset-related administrative expenses related to the operations of the Separate Account. Optional benefit charges may be elected for a guaranteed minimum death benefit and an earnings enhancement benefit. Symetra Life deducts a daily charge from the assets of the Separate Account to cover these expenses. These charges are included in net investment income (loss) in the accompanying Statements of Operations. Symetra Life also deducts annual contract maintenance charges which are reflected as a contract maintenance charge in the accompanying Statements of Changes in Net Assets. The periodic table below describes the fees and expenses charged at the product level.

Annual Periodic Charges	Mortality and expense risk charge			Asset-related administrative expenses			Optional guaranteed minimum death benefit			Optional earnings enhancement benefit			Contract Maintenance
		(As a percentage of avg daily net assets of each sub-account deducted daily)			(As a percentage of avg daily net assets of each sub-account deducted daily)
Spinnaker & Mainsail		1.25	%		0.15	%		0.20	%		0.15	%	$	30
Spinnaker Advisor		1.25	%		0.20	%		-			-		$	30
Spinnaker Choice		1.40	%		0.15	%		0.20	%		0.15	%		-
Focus		1.10	%		0.40	%		0.10	%		-		$	40
Retirement Passport		1.25	%		-			-			-		$	30
Retirement Passport — Calvert sub accounts		1.25	%		0.10	%		-			-		$	30
Retirement Passport — Vanguard sub accounts		1.25	%		0.25	%		-			-		$	30

A withdrawal charge of $25 or 2.00 percent of the withdrawal amount, whichever is less, may be imposed on the owner of the policy for the second and each subsequent withdrawal in any one year. A transfer charge of $10 or 2.00 percent of the amount transferred, whichever is less, may be imposed on transfers that exceed the number of free transfers allowed each year. These charges are reflected as contract maintenance charges in the accompanying Statements of Changes in Net Assets. A surrender charge may be applicable in the first eight years on withdrawals that exceed the free withdrawal amount. The charge is reflected as transfers out in the accompanying Statements of Changes in Net Assets. These charges do not apply to all products and may vary by contract year and other factors as described in the product prospectuses.

The Passport product may allow the owner of the policy to take a loan against their account value. A loan application charge of $50 or 2.50 percent of the loan amount, whichever is less, will deducted from the sub-account with the highest balance at the time the is loan is approved. An annual loan maintenance charge of $35 or 2.50 percent of the loan amount, whichever is less, will be deducted from the sub-account with the highest balance. These charges are reflected as transfers out in the accompanying Statements of Changes in Net Assets.

4.  INVESTMENT TRANSACTIONS

The following table summarizes investment purchases and proceeds from sales activity by sub-account for the year ended December 31, 2009. The table also summarizes underlying investment information for each sub-account as of December 31, 2009.

	Year Ended					As of December 31, 2009
	December 31, 2009					Investments						Net Asset
Sub-Account	Purchases		Proceeds from Sales			at Cost		at Fair Value		Shares Owned		Value2
AIM Capital Appreciation I	$	434,478	$	(897,025	)	$	6,274,485	$	5,065,335		249,157	$	20.33
AIM Capital Appreciation II		238,712		(228,016	)		965,851		880,025		44,001		20.00
AIM Capital Development Series I		23,096		(53,224	)		344,741		274,734		24,334		11.29
AIM Capital Development Series II		168,174		(113,272	)		739,480		643,078		58,516		10.99
AIM Global Healthcare		42,011		(121,729	)		584,819		541,569		34,126		15.87
AIM Global Real Estate		1,144,115		(1,557,912	)		11,515,667		8,051,298		663,204		12.14
AIM International Growth I		283,104		(383,464	)		2,164,131		2,157,316		82,942		26.01
AIM International Growth II		2,650,532		(1,401,487	)		8,452,484		8,394,202		327,516		25.63
AIM Small Cap Equity II		46,861		(13,612	)		60,465		71,957		5,670		12.69
American Century Balanced		1,678,261		(2,518,374	)		13,048,315		11,488,515		1,998,003		5.75

124

Symetra Separate Account C

Notes to Financial Statements

4.  INVESTMENT TRANSACTIONS (Continued)

	Year Ended					As of December 31, 2009
	December 31, 2009					Investments						Net Asset
Sub-Account	Purchases		Proceeds from Sales			at Cost		at Fair Value		Shares Owned		Value2
American Century Inflation Protection II	$	1,774,538	$	(1,453,333	)	$	4,659,067	$	4,787,088		446,142	$	10.73
American Century International		1,313,580		(2,023,073	)		13,155,623		11,472,255		1,484,121		7.73
American Century Large Company Value II		174,255		(177,323	)		470,391		469,802		54,501		8.62
American Century Ultra I		63,582		(54,776	)		480,071		428,016		52,710		8.12
American Century Ultra II		88,911		(78,184	)		114,027		113,879		14,165		8.04
American Century Value		978,785		(658,832	)		4,525,790		3,879,529		734,760		5.28
Dreyfus Appreciation		767,838		(734,195	)		5,061,098		4,550,443		144,918		31.40
Dreyfus Midcap Stock		1,485,038		(2,330,782	)		16,283,551		12,328,303		1,178,615		10.46
Dreyfus Quality Bond		810,290		(1,559,519	)		5,472,437		5,524,111		498,567		11.08
Dreyfus Socially Responsible		515,909		(638,685	)		3,397,475		3,333,839		126,956		26.26
Dreyfus Stock Index		4,039,386		(3,653,944	)		16,369,531		14,249,828		540,997		26.34
Dreyfus Technology Growth		469,626		(665,902	)		2,787,236		3,103,812		310,692		9.99
DWS Balanced VIP A		998,281		(2,504,025	)		14,129,991		12,515,968		609,941		20.52
DWS Capital Growth VIP B		994,115		(213,271	)		1,304,460		1,518,564		90,069		16.86
DWS Global Opportunities B Share		58,053		(3,837	)		54,231		57,196		5,147		11.11
DWS Global Thematic B Share		22,272		(248	)		25,089		29,906		3,625		8.25
DWS International VIP A		352,322		(755,410	)		6,766,550		4,665,493		564,830		8.26
DWS Small Cap Index A Share		37,109		(992	)		53,603		58,666		5,927		9.90
Federated Capital Income		149,906		(424,732	)		1,802,424		1,641,522		189,333		8.67
Federated High Income Bond		533,069		(685,847	)		3,453,500		3,372,759		505,659		6.67
Federated International Equity		68,888		(268,420	)		1,205,910		987,910		71,795		13.76
Fidelity Asset Manager		49,988		(70,198	)		528,431		475,953		36,612		13.00
Fidelity Contrafund		4,567,092		(4,158,854	)		36,615,120		29,247,525		1,418,405		20.62
Fidelity Equity Income		1,666,545		(1,554,951	)		10,369,250		8,250,718		490,820		16.81
Fidelity Freedom Funds 2010 II		36,508		(1,179	)		97,369		99,412		10,207		9.74
Fidelity Freedom Funds 2015 II		45,050		(3,857	)		61,173		66,135		6,791		9.74
Fidelity Freedom Funds 2020 II		53,603		(12,137	)		473,203		532,403		56,161		9.48
Fidelity Freedom Funds 2025 II		195,272		(15,908	)		213,182		247,709		26,721		9.27
Fidelity Freedom Funds 2030 II		142,167		(86,111	)		118,858		136,070		15,118		9.00
Fidelity Freedom Income Fund II		6,675		(4,627	)		54,029		52,581		5,273		9.97
Fidelity Growth		1,266,745		(2,320,594	)		14,296,708		12,543,911		417,575		30.04
Fidelity Growth & Income		957,896		(1,515,127	)		8,355,847		6,908,971		624,117		11.07
Fidelity Growth Opportunities		219,523		(486,504	)		3,661,471		3,072,473		211,748		14.51
Fidelity Index 500		173,946		(125,940	)		308,349		334,746		2,799		119.62
Fidelity Mid-Cap Advisor II		1,853,291		(1,545,446	)		8,419,861		7,874,558		313,729		25.10
Fidelity Money Market Fund		3,508,470		(2,457,034	)		2,313,343		2,313,343		2,313,343		1.00
Fidelity Overseas II		111,007		(62,681	)		114,963		107,139		7,180		14.92
Fidelity VIP Money Market Service Class		19,419,863		(18,265,736	)		13,096,560		13,096,560		13,096,560		1.00
Franklin Flex Cap Growth Securities		106,054		(57,934	)		248,376		265,167		24,258		10.93
Franklin Founding Allocation Fund Class II		183,160		(41,099	)		335,990		360,879		50,544		7.14
Franklin Income Securities Fund Class II		1,267,797		(1,584,670	)		6,773,327		6,152,725		435,745		14.12
Franklin Small Cap Value Fund II		2,959,111		(1,484,705	)		6,110,187		6,188,664		484,626		12.77
Franklin Small-Mid Cap Growth II		730,934		(898,335	)		5,738,935		4,923,658		291,859		16.87
Franklin U.S. Government II		5,673,901		(5,903,031	)		17,094,867		17,433,171		1,354,559		12.87
Ibbotson Aggressive Growth Class I		227,165		(98,937	)		322,871		352,275		43,545		8.09

125

Symetra Separate Account C

Notes to Financial Statements

4.  INVESTMENT TRANSACTIONS (Continued)

	Year Ended					As of December 31, 2009
	December 31, 2009					Investments						Net Asset
Sub-Account	Purchases		Proceeds from Sales			at Cost		at Fair Value		Shares Owned		Value2
Ibbotson Aggressive Growth Class II	$	686,216	$	(60,356	)	$	1,721,329	$	1,918,495		238,027	$	8.06
Ibbotson Balanced Class I		556,503		(468,475	)		1,153,134		1,199,317		132,084		9.08
Ibbotson Balanced Class II		3,039,450		(213,681	)		3,102,034		3,564,722		388,737		9.17
Ibbotson Conservative Class I		5,116		(7,485	)		159,195		162,894		15,455		10.54
Ibbotson Conservative Class II		538,882		(40,954	)		515,356		557,075		52,853		10.53
Ibbotson Growth Class I		302,156		(485,076	)		502,643		498,546		57,970		8.60
Ibbotson Growth Class II		1,488,547		(205,021	)		1,547,052		1,781,259		208,823		8.53
Ibbotson Income and Growth Class I		19,452		(14,921	)		233,008		220,550		23,313		9.46
Ibbotson Income and Growth Class II		917,529		(130,352	)		890,834		955,696		97,321		9.82
ING Global Resources		104,232		(313,885	)		2,128,753		1,734,738		97,130		17.86
ING JP Morgan Emerging Markets Equity I		50,163		(334,470	)		1,170,901		1,731,630		84,967		20.38
JP Morgan Insurance Trust International Equity I1		10,873,162		(1,127,942	)		9,282,754		7,728,524		810,116		9.54
JP Morgan Insurance Trust Mid Cap Value I1		7,244,803		(879,900	)		6,024,002		5,120,208		919,248		5.57
JP Morgan Insurance Trust U.S. Equity I1		3,735,576		(346,379	)		3,334,810		3,273,423		234,991		13.93
JP Morgan International Equity1		1,170,142		(10,949,144	)		-		-		-		-
JP Morgan Mid-Cap Value1		311,766		(7,189,289	)		-		-		-		-
JP Morgan US Large Cap Core Equity1		119,949		(3,765,448	)		-		-		-		-
Mutual Shares Securities		1,442,249		(1,214,887	)		9,494,010		7,880,369		540,494		14.58
Neuberger Berman AMT Guardian Class S		16,581		(11,507	)		48,557		47,820		3,010		15.89
Neuberger Berman AMT Mid Cap Growth Class S		209,845		(58,114	)		334,435		386,073		18,497		20.87
Neuberger Berman AMT Regency Class S		13,802		(84	)		13,746		16,575		1,255		13.21
PIMCO All Asset Portfolio Advisor		309,452		(168,735	)		419,691		449,016		42,762		10.50
PIMCO Commodity Fund Admin		1,685,101		(733,119	)		4,326,368		3,594,089		417,918		8.60
Pioneer Bond VCT Class I		528,194		(1,066,567	)		4,959,458		5,213,401		457,717		11.39
Pioneer Emerging Markets VCT Class II		1,165,973		(821,168	)		3,719,990		3,762,593		139,666		26.94
Pioneer Equity Income VCT Class II		1,464,828		(786,401	)		4,050,155		3,711,918		220,293		16.85
Pioneer Fund VCT Class I		2,119,748		(6,812,586	)		48,106,217		41,354,940		2,109,947		19.60
Pioneer Growth Opportunities VCT Class I		1,245,759		(5,453,457	)		47,076,598		40,713,249		2,127,129		19.14
Pioneer High Yield VCT Class II		1,862,438		(2,658,836	)		1,286,773		1,506,267		158,386		9.51
Pioneer Mid-Cap Value VCT Class I		460,342		(1,462,980	)		11,371,306		8,837,994		610,358		14.48
Pioneer Money Market VCT Class I		495,500		(914,152	)		3,564,713		3,564,713		3,564,713		1.00
Pioneer Real Estate VCT Class II		1,169,685		(809,934	)		2,469,149		2,740,099		210,292		13.03
Pioneer Small-Cap Value VCT Class I1		245,678		(6,434,752	)		-		-		-		-
Pioneer Small-Cap Value VCT Class II1		168,005		(1,971,481	)		-		-		-		-
Pioneer Strategic Income VCT Class II		2,218,434		(806,408	)		4,174,180		4,208,133		418,305		10.06
Summit Balance Index		210,634		(159,991	)		58,716		64,254		1,415		45.42
Summit Barclays Aggregate Bond Index		984,454		(125,096	)		1,146,110		1,121,129		22,062		50.82
Summit EAFE International Index F Class		94,743		(12,740	)		85,051		85,371		1,165		73.19

126

Symetra Separate Account C

Notes to Financial Statements

4.  INVESTMENT TRANSACTIONS (Continued)

	Year Ended					As of December 31, 2009
	December 31, 2009					Investments						Net Asset
Sub-Account	Purchases		Proceeds from Sales			at Cost		at Fair Value		Shares Owned		Value2
Summit NASDAQ 100 Index	$	89,215	$	(34,953	)	$	64,746	$	86,220		3,380	$	25.51
Summit Russell 2000 Small Cap Index F Class		555,293		(118,575	)		623,997		787,762		15,638		50.38
Summit S&P Mid Cap 400 Index F Class		133,684		(122,588	)		60,469		75,818		1,376		55.10
Templeton Developing Markets II		1,103,203		(964,838	)		6,112,403		5,504,297		562,811		9.78
Templeton Global Bond Securities II1		2,883,527		(930,196	)		5,943,608		6,143,719		354,514		17.33
Templeton Growth Securities II		1,012,696		(734,911	)		7,374,019		5,973,934		574,419		10.40
Vanguard Balanced		163,650		(36,746	)		817,013		788,683		45,458		17.35
Vanguard High Yield Bond		281,634		(158,204	)		775,719		836,784		112,170		7.46
Vanguard International		521,268		(131,264	)		1,131,715		1,254,612		78,119		16.06
Vanguard Mid-Cap Index		610,631		(539,164	)		1,527,998		1,678,612		139,651		12.02
Vanguard REIT Index		189,813		(138,385	)		404,969		443,210		53,398		8.30
Vanguard Total Bond Market Index		1,655,012		(687,497	)		3,846,300		3,969,815		337,282		11.77
Vanguard Total Stock Market Index		1,046,034		(733,844	)		2,394,368		2,587,251		119,063		21.73
Wanger USA		2,520		(72,590	)		292,898		325,191		11,846		27.45

  ¹  Reference Note 1 for name changes, reorganizations and commencement dates.

  ²  Net asset values represent the amounts published by the underlying mutual funds and may differ slightly due to rounding to those amounts calculated from the information presented in the financial statements.

5.  CHANGES IN ACCUMULATION UNITS OUTSTANDING

The changes in Units outstanding for the years ended December 31, 2009, and 2008 were as follows:

	2009								2008
Sub-Account	Units Issued		Units Redeemed			Increase (Decrease) in Units			Units Issued		Units Redeemed			Increase (Decrease) in Units
Spinnaker & Mainsail
AIM Capital Appreciation I		61,236		(122,105	)		(60,869	)		53,518		(138,614	)		(85,096	)
AIM Capital Appreciation II		29,295		(27,079	)		2,216			52,037		(17,362	)		34,675
AIM Capital Development Series I		1,338		(3,626	)		(2,288	)		3,586		(3,257	)		329
AIM Capital Development Series II		22,216		(15,403	)		6,813			25,986		(25,229	)		757
AIM Global Healthcare		3,352		(8,043	)		(4,691	)		4,038		(13,985	)		(9,947	)
AIM Global Real Estate		63,617		(66,761	)		(3,144	)		45,104		(125,366	)		(80,262	)
AIM International Growth I		14,181		(18,024	)		(3,843	)		16,209		(18,316	)		(2,107	)
AIM International Growth II		255,084		(144,434	)		110,650			349,443		(104,824	)		244,619
AIM Small Cap Equity II		5,950		(1,423	)		4,527			1,409		-			1,409
American Century Balanced		94,167		(170,707	)		(76,540	)		120,216		(262,375	)		(142,159	)
American Century Inflation Protection II		123,296		(98,036	)		25,260			151,067		(69,298	)		81,769
American Century International		133,153		(219,206	)		(86,053	)		163,390		(252,978	)		(89,588	)
American Century Large Company Value II		19,131		(9,455	)		9,676			20,114		(16,465	)		3,649
American Century Ultra I		6,698		(5,704	)		994			8,368		(28,860	)		(20,493	)
American Century Ultra II		4,586		(3,345	)		1,241			10,956		(8,218	)		2,738
American Century Value		68,925		(53,596	)		15,329			81,739		(101,658	)		(19,919	)
Dreyfus Appreciation		34,711		(68,150	)		(33,439	)		50,085		(131,926	)		(81,841	)
Dreyfus Midcap Stock		126,077		(186,935	)		(60,858	)		125,590		(243,115	)		(117,525	)
Dreyfus Quality Bond		37,688		(82,949	)		(45,261	)		44,026		(120,573	)		(76,547	)

127

Symetra Separate Account C

Notes to Financial Statements

5.  CHANGES IN ACCUMULATION UNITS OUTSTANDING (Continued)

	2009								2008
Sub-Account	Units Issued		Units Redeemed			Increase (Decrease) in Units			Units Issued		Units Redeemed			Increase (Decrease) in Units
Spinnaker & Mainsail (Continued)
Dreyfus Socially Responsible		79,382		(114,036	)		(34,654	)		126,361		(115,232	)		11,129
Dreyfus Stock Index		240,782		(263,854	)		(23,072	)		241,930		(215,719	)		26,211
Dreyfus Technology Growth		110,241		(200,180	)		(89,939	)		175,916		(204,394	)		(28,478	)
DWS Balanced VIP A		26,116		(104,662	)		(78,546	)		34,784		(141,336	)		(106,552	)
DWS Capital Growth VIP B		114,784		(22,932	)		91,852			70,950		(4,450	)		66,500
DWS Global Opportunities B Share		5,530		(138	)		5,392			6		-			6
DWS Global Thematic B Share		3,380		(11	)		3,369			3,939		(3,333	)		606
DWS International VIP A		12,629		(48,635	)		(36,006	)		14,871		(60,592	)		(45,721	)
Federated Capital Income		3,653		(29,654	)		(25,999	)		9,469		(40,601	)		(31,132	)
Federated High Income Bond		11,759		(32,708	)		(20,949	)		8,943		(56,164	)		(47,221	)
Federated International Equity		3,267		(18,242	)		(14,975	)		4,236		(23,912	)		(19,676	)
Fidelity Asset Manager		3,439		(3,303	)		136			5,144		(2,754	)		2,390
Fidelity Contrafund		285,285		(270,896	)		14,389			338,796		(411,185	)		(72,389	)
Fidelity Equity Income		138,923		(135,118	)		3,805			151,021		(139,524	)		11,497
Fidelity Freedom Funds 2010 II		3,220		(4	)		3,216			2,395		-			2,395
Fidelity Freedom Funds 2015 II		4,953		(466	)		4,487			1,198		(4	)		1,194
Fidelity Freedom Funds 2020 II		3,495		(901	)		2,594			57,131		(4	)		57,127
Fidelity Freedom Funds 2025 II		16,166		(1,857	)		14,309			-		-			-
Fidelity Freedom Funds 2030 II		8,894		(8,203	)		691			9,798		(5	)		9,793
Fidelity Freedom Income Fund II		56		(449	)		(393	)		5,249		-			5,249
Fidelity Growth		227,622		(407,219	)		(179,597	)		217,705		(351,898	)		(134,193	)
Fidelity Growth & Income		113,387		(160,571	)		(47,184	)		116,096		(133,084	)		(16,988	)
Fidelity Growth Opportunities		35,629		(76,196	)		(40,567	)		39,499		(115,131	)		(75,632	)
Fidelity Mid-Cap Advisor II		144,044		(121,183	)		22,861			189,770		(86,990	)		102,780
Fidelity Overseas II		15,873		(7,788	)		8,085			2,887		(85	)		2,802
Fidelity VIP Money Market Service Class		1,195,125		(887,765	)		307,360			1,177,411		(924,103	)		253,308
Franklin Flex Cap Growth Securities		11,483		(3,110	)		8,373			5,592		(1,786	)		3,806
Franklin Founding Allocation Fund Class II		23,832		(3,333	)		20,499			16,804		(177	)		16,627
Franklin Income Securities Fund Class II		77,460		(79,063	)		(1,603	)		149,667		(118,358	)		31,309
Franklin Small Cap Value Fund II		271,667		(148,310	)		123,357			140,999		(57,685	)		83,314
Franklin Small-Mid Cap Growth II		118,751		(125,343	)		(6,592	)		123,609		(170,597	)		(46,988	)
Franklin U.S. Government II		239,720		(291,628	)		(51,908	)		261,475		(283,886	)		(22,411	)
Ibbotson Aggressive Growth Class II		97,418		(5,587	)		91,831			139,047		(462	)		138,585
Ibbotson Balanced Class II		339,230		(21,638	)		317,592			41,957		(7,516	)		34,441
Ibbotson Conservative Class II		26,388		(1,193	)		25,195			1,733		-			1,733
Ibbotson Growth Class II		175,196		(8,009	)		167,187			34,785		(7,108	)		27,677
Ibbotson Income and Growth Class II		81,473		(12,310	)		69,163			11,777		(7	)		11,770
ING Global Resources		3,627		(10,026	)		(6,399	)		5,619		(21,297	)		(15,678	)
ING JP Morgan Emerging Markets Equity I		1,863		(20,541	)		(18,678	)		2,938		(19,600	)		(16,662	)
JP Morgan Insurance Trust International Equity I1		458,305		(65,578	)		392,727			-		-			-
JP Morgan Insurance Trust Mid Cap Value I1		337,386		(50,478	)		286,908			-		-			-
JP Morgan Insurance Trust U.S. Equity I1		233,148		(27,673	)		205,475			-		-			-
JP Morgan International Equity1		46,704		(478,239	)		(431,535	)		90,135		(82,948	)		7,187

128

Symetra Separate Account C

Notes to Financial Statements

5.  CHANGES IN ACCUMULATION UNITS OUTSTANDING (Continued)

	2009								2008
Sub-Account	Units Issued		Units Redeemed			Increase (Decrease) in Units			Units Issued		Units Redeemed			Increase (Decrease) in Units
Spinnaker & Mainsail (Continued)
JP Morgan Mid-Cap Value1		16,601		(332,561	)		(315,960	)		62,700		(102,642	)		(39,942	)
JP Morgan US Large Cap Core Equity1		6,170		(238,707	)		(232,537	)		19,903		(68,464	)		(48,561	)
Mutual Shares Securities		113,173		(106,282	)		6,891			144,576		(130,372	)		14,204
Neuberger Berman AMT Guardian Class S		2,291		(1,648	)		643			5,245		(169	)		5,076
Neuberger Berman AMT Mid Cap Growth Class S		26,552		(6,666	)		19,886			26,531		(2,703	)		23,828
Neuberger Berman AMT Regency Class S		2,069		-			2,069			-		-			-
PIMCO All Asset Portfolio Advisor		28,671		(14,532	)		14,139			17,215		(9,642	)		7,573
PIMCO Commodity Fund Admin		122,662		(63,531	)		59,131			147,874		(100,233	)		47,641
Pioneer Bond VCT Class I		7,540		(28,479	)		(20,939	)		12,884		(47,027	)		(34,143	)
Pioneer Emerging Markets VCT Class II		67,198		(48,736	)		18,462			79,076		(67,806	)		11,270
Pioneer Equity Income VCT Class II		148,121		(75,183	)		72,937			112,987		(84,281	)		28,706
Pioneer Fund VCT Class I		35,534		(154,424	)		(118,890	)		40,938		(207,392	)		(166,454	)
Pioneer Growth Opportunities VCT Class I		36,082		(138,164	)		(102,082	)		47,637		(234,015	)		(186,379	)
Pioneer High Yield VCT Class II		64,305		(53,217	)		11,088			49,981		(27,693	)		22,289
Pioneer Mid-Cap Value VCT Class I		18,153		(73,383	)		(55,230	)		30,327		(114,549	)		(84,221	)
Pioneer Money Market VCT Class I		22,814		(41,536	)		(18,722	)		18,092		(50,982	)		(32,890	)
Pioneer Real Estate VCT Class II		190,950		(121,897	)		69,053			130,207		(75,725	)		54,482
Pioneer Small-Cap Value VCT Class I1		12,335		(403,218	)		(390,883	)		28,410		(143,027	)		(114,617	)
Pioneer Small-Cap Value VCT Class II1		22,330		(253,217	)		(230,887	)		60,172		(66,307	)		(6,136	)
Pioneer Strategic Income VCT Class II		131,046		(53,655	)		77,391			121,462		(53,163	)		68,299
Summit Balance Index		13,060		(6,422	)		6,638			305		-			305
Summit Barclays Aggregate Bond Index		74,148		(9,728	)		64,420			30,910		(4,397	)		26,513
Summit EAFE International Index F Class		4,886		(1,749	)		3,137			23		-			23
Summit NASDAQ 100 Index		11,818		(4,865	)		6,953			1,346		(1	)		1,345
Summit Russell 2000 Small Cap Index F Class		65,264		(11,970	)		53,294			23,704		(2,401	)		21,303
Summit S&P Mid Cap 400 Index F Class		21,149		(14,281	)		6,868			1,965		-			1,965
Templeton Developing Markets II		49,394		(45,219	)		4,175			43,711		(46,378	)		(2,667	)
Templeton Global Bond Securities II1		134,971		(58,881	)		76,090			215,761		(68,089	)		147,672
Templeton Growth Securities II		91,167		(66,923	)		24,244			102,992		(84,595	)		18,397
Wanger USA		85		(1,930	)		(1,845	)		313		(1,213	)		(900	)
Spinnaker Advisor
AIM Capital Appreciation I		3,196		(9,542	)		(6,346	)		3,272		(11,634	)		(8,362	)
AIM Capital Appreciation II		1,151		(891	)		260			4,393		(1,845	)		2,548
AIM Capital Development Series I		658		(1,192	)		(534	)		624		(1,146	)		(522	)
AIM Capital Development Series II		2,370		(748	)		1,622			270		(1,443	)		(1,173	)
AIM Global Healthcare		189		(2,353	)		(2,164	)		1,092		(5,484	)		(4,392	)
AIM Global Real Estate		7,691		(26,995	)		(19,304	)		10,971		(27,229	)		(16,258	)
AIM International Growth I		701		(3,169	)		(2,468	)		1,251		(8,208	)		(6,957	)
AIM International Growth II		43,309		(10,945	)		32,364			29,674		(45,164	)		(15,490	)
AIM Small Cap Equity II		1,128		(553	)		575			2,001		(2	)		1,999
American Century Balanced		10,956		(62,127	)		(51,171	)		48,224		(88,528	)		(40,304	)
American Century Inflation Protection II		32,331		(31,335	)		996			65,490		(81,084	)		(15,594	)

129

Symetra Separate Account C

Notes to Financial Statements

5.  CHANGES IN ACCUMULATION UNITS OUTSTANDING (Continued)

	2009								2008
Sub-Account	Units Issued		Units Redeemed			Increase (Decrease) in Units			Units Issued		Units Redeemed			Increase (Decrease) in Units
Spinnaker Advisor (Continued)
American Century International		13,591		(30,889	)		(17,298	)		47,628		(68,707	)		(21,079	)
American Century Large Company Value II		1,536		(12,517	)		(10,981	)		450		(8,532	)		(8,082	)
American Century Ultra I		-		(2	)		(2	)		342		(10,461	)		(10,119	)
American Century Ultra II		6,374		(6,362	)		12			34		(359	)		(325	)
American Century Value		9,918		(6,344	)		3,575			4,946		(9,062	)		(4,116	)
Dreyfus Appreciation		9,884		(18,810	)		(8,926	)		19,787		(29,112	)		(9,324	)
Dreyfus Midcap Stock		26,725		(69,207	)		(42,482	)		45,677		(122,345	)		(76,668	)
Dreyfus Quality Bond		3,458		(31,672	)		(28,214	)		6,675		(42,686	)		(36,011	)
Dreyfus Socially Responsible		20,425		(4,809	)		15,616			19,980		(10,170	)		9,810
Dreyfus Stock Index		59,906		(76,441	)		(16,535	)		85,740		(156,386	)		(70,646	)
Dreyfus Technology Growth		40,793		(7,591	)		33,202			7,641		(18,208	)		(10,567	)
DWS Balanced VIP A		7,661		(52,327	)		(44,666	)		28,280		(36,264	)		(7,984	)
DWS Capital Growth VIP B		24,732		(3,678	)		21,054			666		(31	)		635
DWS Global Opportunities B Share		2,425		(393	)		2,032			-		-			-
DWS International VIP A		498		(9,819	)		(9,321	)		2,973		(21,037	)		(18,064	)
Federated Capital Income		40		(937	)		(897	)		40		(2,388	)		(2,348	)
Federated High Income Bond		360		(11,652	)		(11,292	)		528		(27,078	)		(26,550	)
Fidelity Asset Manager		121		(2,852	)		(2,731	)		4,654		(690	)		3,964
Fidelity Contrafund		36,867		(21,694	)		15,173			59,566		(47,471	)		12,095
Fidelity Equity Income		13,270		(12,320	)		950			20,125		(37,697	)		(17,572	)
Fidelity Freedom Funds 2010 II		1,019		-			1,019			4,508		(418	)		4,090
Fidelity Freedom Funds 2015 II		551		-			551			1,008		-			1,008
Fidelity Freedom Funds 2020 II		1,056		-			1,056			-		-			-
Fidelity Freedom Funds 2025 II		11,154		-			11,154			3,160		-			3,160
Fidelity Freedom Funds 2030 II		11,016		(5,106	)		5,910			-		-			-
Fidelity Freedom Income Fund II		383		-			383			-		-			-
Fidelity Growth		22,615		(57,474	)		(34,859	)		53,836		(100,272	)		(46,436	)
Fidelity Growth & Income		12,716		(41,645	)		(28,929	)		16,427		(46,560	)		(30,133	)
Fidelity Growth Opportunities		1,004		(669	)		335			730		(5,443	)		(4,713	)
Fidelity Mid-Cap Advisor II		25,837		(17,419	)		8,418			49,819		(43,043	)		6,776
Fidelity Overseas II		193		(1,414	)		(1,221	)		5,051		-			5,051
Fidelity VIP Money Market Service Class		381,732		(572,533	)		(190,801	)		677,522		(381,199	)		296,323
Franklin Flex Cap Growth Securities		255		(2,531	)		(2,276	)		2		(1	)		1
Franklin Founding Allocation Fund Class II		-		(1,986	)		(1,986	)		8,155		(1,060	)		7,095
Franklin Income Securities Fund Class II		6,317		(50,049	)		(43,732	)		20,291		(34,545	)		(14,254	)
Franklin Small Cap Value Fund II		44,277		(11,169	)		33,108			23,085		(19,261	)		3,824
Franklin Small-Mid Cap Growth II		4,426		(18,239	)		(13,813	)		10,297		(46,652	)		(36,355	)
Franklin U.S. Government II		86,104		(84,075	)		2,029			176,016		(204,563	)		(28,547	)
Ibbotson Aggressive Growth Class II		2,721		-			2,721			-		-			-
Ibbotson Balanced Class II		45,123		(1,048	)		44,075			-		-			-
Ibbotson Conservative Class II		32,109		(2,590	)		29,519			-		-			-
Ibbotson Growth Class II		23,143		(16,306	)		6,837			6,589		(90	)		6,499
Ibbotson Income and Growth Class II		22,309		(2,034	)		20,275			-		-			-
ING Global Resources		312		(2,434	)		(2,122	)		1,679		(7,677	)		(5,998	)

130

Symetra Separate Account C

Notes to Financial Statements

5.  CHANGES IN ACCUMULATION UNITS OUTSTANDING (Continued)

	2009								2008
Sub-Account	Units Issued		Units Redeemed			Increase (Decrease) in Units			Units Issued		Units Redeemed			Increase (Decrease) in Units
Spinnaker Advisor (Continued)
JP Morgan Insurance Trust International Equity I1		67,746		(5,051	)		62,695			-		-			-
JP Morgan Insurance Trust Mid Cap Value I1		60,127		(12,041	)		48,086			-		-			-
JP Morgan Insurance Trust U.S. Equity I1		245,309		(19,039	)		226,270			-		-			-
JP Morgan International Equity1		6,486		(75,119	)		(68,633	)		12,568		(23,530	)		(10,962	)
JP Morgan Mid-Cap Value1		1,408		(67,447	)		(66,039	)		4,719		(38,985	)		(34,266	)
JP Morgan US Large Cap Core Equity1		4,081		(248,344	)		(244,263	)		20,073		(61,190	)		(41,117	)
Mutual Shares Securities		18,767		(9,082	)		9,685			15,390		(17,635	)		(2,245	)
Neuberger Berman AMT Guardian Class S		19		-			19			10		(1	)		9
Neuberger Berman AMT Mid Cap Growth Class S		5,648		(1,326	)		4,322			31		-			31
PIMCO All Asset Portfolio Advisor		252		-			252			417		-			417
PIMCO Commodity Fund Admin		33,821		(18,537	)		15,284			32,545		(41,610	)		(9,065	)
Pioneer Bond VCT Class I		1,689		(12,885	)		(11,196	)		3,075		(18,868	)		(15,793	)
Pioneer Emerging Markets VCT Class II		12,876		(4,082	)		8,794			32,509		(30,037	)		2,472
Pioneer Equity Income VCT Class II		16,305		(10,103	)		6,202			7,322		(11,816	)		(4,494	)
Pioneer Fund VCT Class I		4,936		(15,565	)		(10,629	)		5,867		(14,758	)		(8,891	)
Pioneer Growth Opportunities VCT Class I		4,958		(30,782	)		(25,824	)		9,352		(46,965	)		(37,613	)
Pioneer High Yield VCT Class II		24,327		(13,664	)		10,664			3,387		(4,955	)		(1,568	)
Pioneer Mid-Cap Value VCT Class I		889		(5,221	)		(4,332	)		1,349		(10,702	)		(9,353	)
Pioneer Money Market VCT Class I		5,578		(7,552	)		(1,974	)		3,532		(8,740	)		(5,208	)
Pioneer Real Estate VCT Class II		20,458		(12,128	)		8,330			31,757		(16,774	)		14,983
Pioneer Small-Cap Value VCT Class I1		2,531		(88,650	)		(86,119	)		5,370		(38,451	)		(33,081	)
Pioneer Small-Cap Value VCT Class II1		2,074		(41,344	)		(39,270	)		14,079		(40,656	)		(26,577	)
Pioneer Strategic Income VCT Class II		27,446		(18,321	)		9,125			59,551		(42,130	)		17,421
Summit Balance Index		11,996		(11,996	)		-			-		-			-
Summit Barclays Aggregate Bond Index		14,076		(1,357	)		12,719			1,564		(107	)		1,457
Summit EAFE International Index F Class		8,361		-			8,361			-		-			-
Summit NASDAQ 100 Index		802		-			802			-		-			-
Summit Russell 2000 Small Cap Index F Class		15,622		(2,528	)		13,094			3,327		-			3,327
Templeton Developing Markets II		8,495		(9,716	)		(1,221	)		6,206		(32,186	)		(25,980	)
Templeton Global Bond Securities II1		27,941		(6,728	)		21,213			33,319		(50,980	)		(17,661	)
Templeton Growth Securities II		1,281		(3,899	)		(2,618	)		2,793		(3,966	)		(1,173	)
Spinnaker with EEB
AIM Capital Development Series II		98		-			98			98		-			98
AIM International Growth II		79		-			79			81		-			81
American Century Balanced		122		-			122			139		-			139
American Century International		312		-			312			298		-			298
American Century Ultra I		57		-			57			59		-			59
Dreyfus Stock Index		196		-			196			196		-			196
Fidelity Equity Income		92		-			92			89		-			89

131

Symetra Separate Account C

Notes to Financial Statements

5.  CHANGES IN ACCUMULATION UNITS OUTSTANDING (Continued)

	2009								2008
Sub-Account	Units Issued		Units Redeemed			Increase (Decrease) in Units			Units Issued		Units Redeemed			Increase (Decrease) in Units
Spinnaker with EEB (Continued)
Fidelity VIP Money Market Service Class		178		(6	)		172			-		-			-
Franklin U.S. Government II		137		-			137			191		(5	)		186
JP Morgan Insurance Trust Mid Cap Value I1		249		-			249			-		-			-
JP Morgan Mid-Cap Value1		36		(210	)		(174	)		78		-			78
PIMCO Commodity Fund Admin		67		-			67			57		-			57
Pioneer Real Estate VCT Class II		97		-			97			82		-			82
Pioneer Small-Cap Value VCT Class II1		45		(239	)		(194	)		91		-			91
Spinnaker with GMDB
AIM Global Real Estate		-		(1	)		(1	)		-		-			-
AIM International Growth I		-		(2	)		(2	)		-		-			-
AIM International Growth II		177		(4	)		173			263		(11	)		252
American Century Balanced		-		(3	)		(3	)		-		(4	)		(4	)
American Century International		2		(33	)		(31	)		2		(1	)		1
American Century Large Company Value II		5		-			5			4		-			4
Dreyfus Appreciation		-		-			-			73		(1	)		72
Dreyfus Midcap Stock		-		(5	)		(5	)		-		-			-
Dreyfus Stock Index		70		(13	)		57			52		(3	)		49
Fidelity Contrafund		3		(49	)		(46	)		43		(2	)		41
Fidelity Equity Income		7		(5	)		2			6		(1	)		5
Fidelity Growth		-		(4	)		(4	)		-		(3	)		(3	)
Fidelity Growth & Income		7		-			7			6		(1	)		5
Fidelity Mid-Cap Advisor II		11		-			11			9		(1	)		8
Fidelity VIP Money Market Service Class		140		(8	)		132			30		(33	)		(3	)
Franklin Income Securities Fund Class II		4		(132	)		(128	)		3		(7	)		(4	)
Franklin Small Cap Value Fund II		5		-			5			65		(1	)		64
JP Morgan Insurance Trust International Equity I1		22		-			22			-		-			-
JP Morgan Insurance Trust Mid Cap Value I1		122		-			122			-		-			-
JP Morgan International Equity1		-		(30	)		(30	)		-		-			-
JP Morgan Mid-Cap Value1		2		(118	)		(116	)		5		-			5
PIMCO Commodity Fund Admin		-		(3	)		(3	)		-		-			-
Pioneer Emerging Markets VCT Class II		3		(3	)		-			2		(2	)		-
Pioneer Equity Income VCT Class II		4		-			4			4		-			4
Pioneer High Yield VCT Class II		-		(19	)		(19	)		-		(1	)		(1	)
Pioneer Small-Cap Value VCT Class I1		-		(87	)		(87	)		-		-			-
Pioneer Small-Cap Value VCT Class II1		-		(55	)		(55	)		-		-			-
Templeton Global Bond Securities II1		-		(109	)		(109	)		-		(1	)		(1	)
Spinnaker Choice
AIM Capital Appreciation II		118		(84	)		34			2,845		(2,637	)		208
AIM Capital Development Series II		-		-			-			20		(162	)		(142	)
AIM Global Real Estate		357		(658	)		(301	)		111		(60	)		51
AIM International Growth I		392		(546	)		(154	)		140		(128	)		12
AIM International Growth II		746		(1,311	)		(565	)		6,650		(46,996	)		(40,346	)
American Century Balanced		545		(1,672	)		(1,127	)		2,085		(2,307	)		(222	)

132

Symetra Separate Account C

Notes to Financial Statements

5.  CHANGES IN ACCUMULATION UNITS OUTSTANDING (Continued)

	2009								2008
Sub-Account	Units Issued		Units Redeemed			Increase (Decrease) in Units			Units Issued		Units Redeemed			Increase (Decrease) in Units
Spinnaker Choice (Continued)
American Century Inflation Protection II		511		(530	)		(19	)		1,776		(570	)		1,206
American Century International		107		(2,055	)		(1,946	)		2,860		(13,739	)		(10,879	)
American Century Large Company Value II		-		(405	)		(405	)		9,449		-			9,449
American Century Ultra I		-		-			-			1		(24	)		(23	)
American Century Value		127		(2	)		125			122		(1,358	)		(1,236	)
Dreyfus Midcap Stock		717		(1,423	)		(706	)		157		(209	)		(52	)
Dreyfus Socially Responsible		373		(189	)		184			4,770		(6,136	)		(1,366	)
Dreyfus Stock Index		1,264		(5,129	)		(3,865	)		5,627		(8,586	)		(2,959	)
Federated Capital Income		-		(9	)		(9	)		-		(7	)		(7	)
Federated High Income Bond		26		(1,686	)		(1,660	)		152		(26	)		126
Fidelity Contrafund		5,838		(2,818	)		3,020			5,009		(9,968	)		(4,959	)
Fidelity Equity Income		861		(1,453	)		(592	)		775		(457	)		318
Fidelity Growth		323		(772	)		(449	)		128		(50	)		78
Fidelity Growth & Income		55		(867	)		(812	)		1,499		(6	)		1,493
Fidelity Mid-Cap Advisor II		11		(999	)		(988	)		838		(340	)		498
Fidelity VIP Money Market Service Class		195,269		(195,994	)		(725	)		548,737		(539,147	)		9,590
Franklin Flex Cap Growth Securities		7		(9	)		(2	)		69		(5,198	)		(5,129	)
Franklin Income Securities Fund Class II		252		(25,226	)		(24,974	)		28		(4,054	)		(4,026	)
Franklin Small Cap Value Fund II		1,052		(132	)		920			2,183		(3,981	)		(1,798	)
Franklin Small-Mid Cap Growth II		188		(819	)		(631	)		1,458		(1,320	)		138
Franklin U.S. Government II		18,309		(8,626	)		9,683			4,643		(11,917	)		(7,274	)
JP Morgan Insurance Trust International Equity I1		4,964		(1,835	)		3,129			-		-			-
JP Morgan Insurance Trust Mid Cap Value I1		3,800		(72	)		3,727			-		-			-
JP Morgan International Equity1		83		(4,578	)		(4,495	)		196		(271	)		(75	)
JP Morgan Mid-Cap Value1		-		(3,800	)		(3,800	)		1,300		(510	)		790
Mutual Shares Securities		454		(290	)		164			26		(736	)		(710	)
PIMCO All Asset Portfolio Advisor		-		-			-			-		(1	)		(1	)
PIMCO Commodity Fund Admin		1,082		(7,217	)		(6,135	)		14,489		(2,775	)		11,714
Pioneer Emerging Markets VCT Class II		13		(909	)		(896	)		2,645		(14,595	)		(11,950	)
Pioneer Equity Income VCT Class II		337		(996	)		(659	)		5,591		(3,265	)		2,326
Pioneer High Yield VCT Class II		103,354		(236,612	)		(133,258	)		576,463		(436,208	)		140,255
Pioneer Real Estate VCT Class II		191		(385	)		(194	)		4,966		(3,148	)		1,818
Pioneer Small-Cap Value VCT Class II1		155		(3,217	)		(3,062	)		411		(883	)		(472	)
Pioneer Strategic Income VCT Class II		1,471		(337	)		1,134			3,132		(4,356	)		(1,224	)
Templeton Developing Markets II		31		(1,073	)		(1,042	)		48		(9,249	)		(9,201	)
Templeton Global Bond Securities II1		175		(592	)		(417	)		5,920		(4,852	)		1,068
Templeton Growth Securities II		44		(1,338	)		(1,294	)		1,178		(1,417	)		(239	)
Spinnaker Choice with GMDB
AIM Capital Appreciation II		36		(6	)		30			20		(2	)		18
AIM Global Real Estate		3		(6	)		(3	)		6		(40	)		(34	)
AIM International Growth II		4		-			4			3		-			3
American Century Inflation Protection II		-		(8	)		(8	)		-		(77	)		(77	)
American Century Ultra I		4		-			4			5		(1	)		4
Dreyfus Midcap Stock		4		(21	)		(17	)		11		(167	)		(156	)
Dreyfus Stock Index		40		(32	)		8			28		(298	)		(270	)

133

Symetra Separate Account C

Notes to Financial Statements

5.  CHANGES IN ACCUMULATION UNITS OUTSTANDING (Continued)

	2009								2008
Sub-Account	Units Issued		Units Redeemed			Increase (Decrease) in Units			Units Issued		Units Redeemed			Increase (Decrease) in Units
Spinnaker Choice with GMDB (Continued)
Fidelity Contrafund		10		(7	)		3			20		(3	)		17
Fidelity Equity Income		6		(27	)		(21	)		12		(199	)		(187	)
Fidelity Growth		12		(11	)		1			6		(92	)		(86	)
Fidelity VIP Money Market Service Class		5		(5	)		-			-		-			-
Franklin Flex Cap Growth Securities		18		(4	)		14			15		(35	)		(20	)
Franklin Income Securities Fund Class II		15		(37	)		(22	)		3		(58	)		55
Franklin U.S. Government II		-		(37	)		(37	)		-		(386	)		(386	)
JP Morgan Insurance Trust International Equity I1		38		(38	)		-			-		-			-
JP Morgan International Equity1		8		(39	)		(31	)		-		(301	)		(301	)
PIMCO Commodity Fund Admin		11		(23	)		(12	)		61		(164	)		(103	)
Pioneer Small-Cap Value VCT Class II1		1		(8	)		(7	)		11		(71	)		(60	)
Templeton Developing Markets II		7		(40	)		(33	)		38		(1	)		37
Templeton Global Bond Securities II1		1		(2	)		(1	)		1		-			1
Focus Tier I
DWS Small Cap Index A Share		713		-			713			-		-			-
Fidelity Index 500		2,868		(67	)		2,801			16,861		(7,681	)		9,180
Fidelity Money Market Fund		180,380		(86,581	)		93,799			261,312		(241,266	)		20,046
Ibbotson Aggressive Growth Class I		25,939		(2,764	)		23,175			14,567		(6,073	)		8,494
Ibbotson Balanced Class I		16,055		(22,508	)		(6,453	)		39,140		(30	)		39,110
Ibbotson Conservative Class I		372		-			372			4,152		-			4,152
Ibbotson Growth Class I		2,701		(4,228	)		(1,527	)		28,034		(4,378	)		23,656
Ibbotson Income and Growth Class I		-		(5	)		(5	)		2,676		-			2,676
Vanguard Balanced		4,288		(479	)		3,809			8,221		(2,026	)		6,195
Vanguard High Yield Bond		7,059		(3,420	)		3,639			17,320		(2,606	)		14,714
Vanguard International		14,288		(7,667	)		6,621			46,243		(14,227	)		32,016
Vanguard Mid-Cap Index		27,755		(13,520	)		14,235			63,865		(13,033	)		50,832
Vanguard REIT Index		10,403		(6,660	)		3,743			20,672		(2,913	)		17,759
Vanguard Total Bond Market Index		24,008		(9,618	)		14,390			48,571		(8,325	)		40,246
Vanguard Total Stock Market Index		40,987		(23,661	)		17,326			81,978		(13,286	)		68,692
Focus Tier II
DWS Small Cap Index A Share		3,252		(62	)		3,190			1,958		-			1,958
Fidelity Index 500		4,431		(812	)		3,619			10,534		(5,255	)		5,279
Fidelity Money Market Fund		36,147		(40,479	)		(4,332	)		217,471		(202,548	)		14,923
Ibbotson Aggressive Growth Class I		1,156		(11,753	)		(10,597	)		11,753		-			11,753
Ibbotson Balanced Class I		53,617		(6,853	)		46,764			6,853		-			6,853
Ibbotson Conservative Class I		28		-			28			6,964		-			6,964
Ibbotson Growth Class I		2,140		-			2,140			-		-			-
Ibbotson Income and Growth Class I		1,893		(1,347	)		546			-		(1,257	)		(1,257	)
Vanguard Balanced		2,232		-			2,232			774		-			774
Vanguard High Yield Bond		3,878		(7,818	)		(3,940	)		24,990		(2,848	)		22,142
Vanguard International		28,917		(6,576	)		22,341			35,026		(8,732	)		26,294
Vanguard Mid-Cap Index		29,226		(17,211	)		12,015			73,624		(11,942	)		61,682
Vanguard REIT Index		11,468		(6,057	)		5,411			27,251		(5,543	)		21,708
Vanguard Total Bond Market Index		20,620		(28,795	)		(8,175	)		106,983		(15,458	)		91,525
Vanguard Total Stock Market Index		50,972		(21,289	)		29,683			114,568		(16,451	)		98,117

134

Symetra Separate Account C

Notes to Financial Statements

5.  CHANGES IN ACCUMULATION UNITS OUTSTANDING (Continued)

	2009								2008
Sub-Account	Units Issued		Units Redeemed			Increase (Decrease) in Units			Units Issued		Units Redeemed			Increase (Decrease) in Units
Focus Tier III
Fidelity Money Market Fund		66,643		(55,530	)		11,113			129,433		(114,956	)		14,477
Ibbotson Aggressive Growth Class I		7,262		-			7,262			-		-			-
Ibbotson Balanced Class I		-		(30,573	)		(30,573	)		28,338		(16,890	)		11,448
Ibbotson Growth Class I		6,823		(48,731	)		(41,908	)		48,731		-			48,731
Vanguard High Yield Bond		10,605		(423	)		10,182			4,078		-			4,078
Vanguard International		17,571		(989	)		16,582			10,424		-			10,424
Vanguard Mid-Cap Index		22,709		(1,092	)		21,617			16,594		-			16,594
Vanguard REIT Index		5,705		(281	)		5,424			6,085		-			6,085
Vanguard Total Bond Market Index		25,751		(14,458	)		11,293			28,732		-			28,732
Vanguard Total Stock Market Index		28,124		(1,329	)		26,795			26,062		-			26,062
Focus Tier I with GMDB
Fidelity Index 500		-		(19,718	)		(19,718	)		19,718		-			19,718
Fidelity Money Market Fund		17,111		(12,634	)		4,477			56,143		(58,471	)		(2,328	)
Ibbotson Conservative Class I		-		(546	)		(546	)		4,821		-			4,821
Ibbotson Growth Class I		4,800		(22,669	)		(17,869	)		41,235		(23,366	)		17,869
Ibbotson Income and Growth Class I		62		(73	)		(11	)		782		-			782
Vanguard Balanced		1		(6	)		(5	)		332		-			332
Vanguard High Yield Bond		2,840		(82	)		2,758			2,274		-			2,274
Vanguard International		2,011		(130	)		1,881			4,745		-			4,745
Vanguard Mid-Cap Index		7,237		(180	)		7,057			10,567		-			10,567
Vanguard REIT Index		804		-			804			1,640		-			1,640
Vanguard Total Bond Market Index		9,615		(60	)		9,555			9,310		-			9,310
Vanguard Total Stock Market Index		12,543		(90	)		12,453			12,235		-			12,235
Focus Tier II with GMDB
DWS Small Cap Index A Share		870		-			870			-		-			-
Fidelity Index 500		19,698		-			19,698			-		-			-
Fidelity Money Market Fund		38,085		(40,530	)		(2,445	)		48,610		(60,409	)		(11,799	)
Ibbotson Balanced Class I		-		-			-			22,817		-			22,817
Ibbotson Growth Class I		22,642		-			22,642			-		-			-
Vanguard Balanced		1,469		(2,938	)		(1,469	)		39,787		(208	)		39,579
Vanguard High Yield Bond		1,198		(2,871	)		(1,673	)		3,006		-			3,006
Vanguard International		5,139		(1,989	)		3,150			2,284		-			2,284
Vanguard Mid-Cap Index		2,345		(6,286	)		(3,941	)		6,388		-			6,388
Vanguard REIT Index		2,886		(713	)		2,173			851		-			851
Vanguard Total Bond Market Index		20,284		(6,150	)		14,134			6,501		-			6,501
Vanguard Total Stock Market Index		16,116		(6,816	)		9,300			7,262		-			7,262
Focus Tier V with GMDB
Vanguard Balanced		8,374		(14	)		8,360			-		-			-
Vanguard High Yield Bond		-		(2,434	)		(2,434	)		-		-			-
Vanguard International		9,746		(466	)		9,280			-		-			-
Vanguard Mid-Cap Index		-		(43,299	)		(43,299	)		-		-			-
Vanguard REIT Index		-		(11,181	)		(11,181	)		-		-			-
Vanguard Total Bond Market Index		35,832		-			35,832			-		-			-
Vanguard Total Stock Market Index		-		(52,408	)		(52,408	)		-		-			-

  ¹  Reference Note 1 for current year name changes, reorganizations and commencement dates.

135

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES

The following table summarizes the Unit values and Units outstanding for sub-accounts by variable annuity contracts, net investment income ratios, and expense ratios, excluding expenses of the underlying funds, and total returns for each of the five years in the period ended December 31, 2009.

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
AIM Capital Appreciation I
Spinnaker & Mainsail
	2009	$	7.387		659,799	$	4,873,775		0.64	%		1.40	%		19.40	%
	2008		6.187		720,668		4,458,618		0.00	%		1.40	%		(43.29	%)
	2007		10.910		805,764		8,791,074		0.00	%		1.40	%		10.45	%
	2006		9.878		969,657		9,571,365		0.06	%		1.40	%		1.22	%
Spinnaker Advisor
	2009		7.373		25,976		191,560		0.60	%		1.45	%		19.34	%
	2008		6.178		32,322		199,728		0.00	%		1.45	%		(43.33	%)
	2007		10.901		40,684		443,536		0.00	%		1.45	%		10.39	%
	2006		9.875		58,618		578,878		0.05	%		1.45	%		1.25	%
AIM Capital Appreciation II
Spinnaker & Mainsail
	2009		9.064		91,608		830,348		0.29	%		1.40	%		19.04	%
	2008		7.614		89,392		680,643		0.00	%		1.40	%		(43.42	%)
	2007		13.458		54,717		736,396		0.00	%		1.40	%		10.17	%
	2006		12.216		9,992		122,060		0.00	%		1.40	%		4.59	%
	2005		11.680		544		6,353		0.00	%		1.40	%		15.53	%
Spinnaker Advisor
	2009		9.043		3,688		33,338		0.29	%		1.45	%		18.99	%
	2008		7.600		3,428		26,043		0.00	%		1.45	%		(43.45	%)
	2007		13.440		880		11,810		0.00	%		1.45	%		10.11	%
	2006		12.206		100		1,215		0.00	%		1.45	%		22.06	%
Spinnaker Choice
	2009		9.000		1,550		13,947		0.28	%		1.55	%		18.86	%
	2008		7.572		1,516		11,470		0.00	%		1.55	%		(43.51	%)
	2007		13.404		1,308		17,531		0.00	%		1.55	%		10.00	%
Spinnaker Choice with GMDB
	2009		8.917		272		2,392		0.30	%		1.75	%		18.62	%
	2008		7.517		242		1,806		0.00	%		1.75	%		(43.62	%)
	2007		13.333		224		2,983		0.00	%		1.75	%		9.78	%
AIM Capital Development Series I
Spinnaker & Mainsail
	2009		14.581		15,819		230,669		0.00	%		1.40	%		40.39	%
	2008		10.386		18,107		188,070		0.00	%		1.40	%		(47.76	%)
	2007		19.883		17,778		353,501		0.00	%		1.40	%		9.29	%
	2006		18.192		17,782		323,497		0.00	%		1.40	%		14.90	%
	2005		15.833		22,168		350,976		0.00	%		1.40	%		8.09	%
Spinnaker Advisor
	2009		14.533		3,032		44,065		0.00	%		1.45	%		40.32	%
	2008		10.357		3,566		36,929		0.00	%		1.45	%		(47.79	%)
	2007		19.837		4,088		81,092		0.00	%		1.45	%		9.24	%
	2006		18.159		3,907		70,946		0.00	%		1.45	%		14.85	%
	2005		15.811		2,424		38,328		0.00	%		1.45	%		8.03	%
AIM Capital Development Series II
Spinnaker & Mainsail
	2009		8.428		70,993		598,385		0.00	%		1.40	%		40.02	%
	2008		6.019		64,180		386,334		0.00	%		1.40	%		(47.87	%)
	2007		11.546		63,423		732,276		0.00	%		1.40	%		9.01	%
	2006		10.592		49,390		523,146		0.00	%		1.40	%		5.92	%

136

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
AIM Capital Development Series II (Continued)
Spinnaker Advisor
	2009	$	8.412		4,810	$	40,457		0.00	%		1.45	%		39.94	%
	2008		6.011		3,188		19,160		0.00	%		1.45	%		(47.89	%)
	2007		11.535		4,361		50,312		0.00	%		1.45	%		8.94	%
	2006		10.588		5,310		56,225		0.00	%		1.45	%		5.88	%
Spinnaker with EEB
	2009		8.380		311		2,595		0.00	%		1.55	%		39.81	%
	2008		5.994		213		1,269		0.00	%		1.55	%		(47.95	%)
	2007		11.515		115		1,318		0.00	%		1.55	%		8.84	%
	2006		10.580		42		444		0.00	%		1.55	%		5.80	%
Spinnaker Choice
	2009		8.380		198		1,641		0.00	%		1.55	%		39.81	%
	2008		5.994		198		1,179		0.00	%		1.55	%		(47.95	%)
	2007		11.515		340		3,920		0.00	%		1.55	%		8.84	%
	2006		10.580		805		8,518		0.00	%		1.55	%		5.80	%
AIM Global Healthcare
Spinnaker & Mainsail
	2009		13.595		32,450		441,169		0.35	%		1.40	%		25.90	%
	2008		10.798		37,141		401,076		0.00	%		1.40	%		(29.62	%)
	2007		15.342		47,088		722,415		0.00	%		1.40	%		10.29	%
	2006		13.910		55,602		773,428		0.00	%		1.40	%		3.77	%
	2005		13.404		59,566		798,417		0.00	%		1.40	%		6.65	%
Spinnaker Advisor
	2009		13.550		7,409		100,400		0.34	%		1.45	%		25.84	%
	2008		10.768		9,573		103,086		0.00	%		1.45	%		(29.65	%)
	2007		15.306		13,965		213,738		0.00	%		1.45	%		10.24	%
	2006		13.885		17,275		239,852		0.00	%		1.45	%		3.73	%
	2005		13.386		21,238		284,286		0.00	%		1.45	%		6.59	%
AIM Global Real Estate
Spinnaker & Mainsail
	2009		21.292		314,516		6,696,861		0.00	%		1.40	%		29.70	%
	2008		16.416		317,660		5,215,023		5.40	%		1.40	%		(45.42	%)
	2007		30.077		397,922		11,968,448		4.99	%		1.40	%		(6.86	%)
	2006		32.292		506,920		16,369,602		1.08	%		1.40	%		40.63	%
	2005		22.963		565,687		12,989,940		1.11	%		1.40	%		12.65	%
Spinnaker Advisor
	2009		20.406		65,825		1,343,307		0.00	%		1.45	%		29.63	%
	2008		15.742		85,129		1,340,125		5.30	%		1.45	%		(45.44	%)
	2007		28.855		101,387		2,925,567		5.02	%		1.45	%		(6.91	%)
	2006		30.996		138,259		4,285,482		1.05	%		1.45	%		40.56	%
	2005		22.052		162,335		3,579,864		1.09	%		1.45	%		12.60	%
Spinnaker with GMDB
	2009		21.051		24		465		0.00	%		1.60	%		29.43	%
	2008		16.264		25		400		6.01	%		1.60	%		(45.53	%)
	2007		29.857		25		737		5.67	%		1.60	%		(7.05	%)
	2006		32.120		25		804		2.28	%		1.60	%		40.34	%
	2005		22.887		2		36		3.61	%		1.60	%		12.43	%
Spinnaker Choice
	2009		14.312		570		8,162		0.00	%		1.55	%		29.50	%
	2008		11.052		871		9,628		6.02	%		1.55	%		(45.50	%)
	2007		20.278		820		16,600		5.53	%		1.55	%		(7.00	%)
	2006		21.805		1,050		22,886		0.61	%		1.55	%		40.41	%
	2005		15.529		2,553		39,651		3.20	%		1.55	%		12.49	%

137

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
AIM Global Real Estate (Continued)
Spinnaker Choice with GMDB
	2009	$	14.151		177	$	2,503		0.00	%		1.75	%		29.24	%
	2008		10.949		180		1,964		5.35	%		1.75	%		(45.61	%)
	2007		20.130		214		4,298		4.53	%		1.75	%		(7.19	%)
	2006		21.689		354		7,681		1.31	%		1.75	%		40.14	%
	2005		15.477		195		3,019		0.00	%		1.75	%		12.26	%
AIM International Growth I
Spinnaker & Mainsail
	2009		20.473		91,769		1,878,781		1.56	%		1.40	%		33.37	%
	2008		15.351		95,612		1,467,770		0.55	%		1.40	%		(41.21	%)
	2007		26.112		97,719		2,551,663		0.42	%		1.40	%		13.12	%
	2006		23.084		97,993		2,262,106		1.10	%		1.40	%		26.45	%
	2005		18.255		77,117		1,407,745		1.08	%		1.40	%		16.30	%
Spinnaker Advisor
	2009		20.404		11,496		234,572		1.52	%		1.45	%		33.29	%
	2008		15.308		13,964		213,766		0.46	%		1.45	%		(41.24	%)
	2007		26.051		20,921		545,027		0.38	%		1.45	%		13.06	%
	2006		23.042		23,997		552,941		1.15	%		1.45	%		26.40	%
	2005		18.230		15,951		290,789		1.00	%		1.45	%		16.23	%
Spinnaker with GMDB
	2009		20.242		-		-		0.09	%		1.60	%		33.10	%
	2008		15.208		2		36		0.00	%		1.60	%		(41.33	%)
	2007		25.921		2		61		0.00	%		1.60	%		12.89	%
	2006		22.961		2		56		2.03	%		1.60	%		26.20	%
	2005		18.194		2		45		2.25	%		1.60	%		16.06	%
Spinnaker Choice
	2009		15.276		2,877		43,963		1.58	%		1.55	%		33.16	%
	2008		11.472		3,031		34,785		0.57	%		1.55	%		(41.30	%)
	2007		19.543		3,019		59,010		0.42	%		1.55	%		12.95	%
	2006		17.303		3,145		54,415		1.22	%		1.55	%		26.27	%
	2005		13.703		1,156		15,837		5.18	%		1.55	%		16.12	%
AIM International Growth II
Spinnaker & Mainsail
	2009		10.348		718,970		7,439,940		1.53	%		1.40	%		33.04	%
	2008		7.778		608,320		4,731,707		0.58	%		1.40	%		(41.38	%)
	2007		13.268		363,701		4,825,454		0.66	%		1.40	%		12.85	%
	2006		11.757		96,051		1,129,294		1.80	%		1.40	%		17.57	%
Spinnaker Advisor
	2009		10.328		84,233		869,993		1.69	%		1.45	%		32.97	%
	2008		7.767		51,869		402,888		0.40	%		1.45	%		(41.41	%)
	2007		13.256		67,359		892,905		0.50	%		1.45	%		12.79	%
	2006		11.753		29,835		350,644		2.32	%		1.45	%		17.53	%
Spinnaker with EEB
	2009		10.289		266		2,693		1.55	%		1.55	%		32.83	%
	2008		7.746		187		1,437		0.61	%		1.55	%		(41.46	%)
	2007		13.232		106		1,386		0.52	%		1.55	%		12.68	%
	2006		11.743		40		463		2.56	%		1.55	%		17.43	%
Spinnaker with GMDB
	2009		10.270		700		7,186		1.55	%		1.60	%		32.77	%
	2008		7.735		527		4,068		0.61	%		1.60	%		(41.49	%)
	2007		13.220		275		3,633		0.42	%		1.60	%		12.62	%
	2006		11.739		126		1,479		1.33	%		1.60	%		17.39	%

138

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
AIM International Growth II (Continued)
Spinnaker Choice
	2009	$	10.289		6,666	$	68,597		1.40	%		1.55	%		32.83	%
	2008		7.746		7,231		56,012		0.25	%		1.55	%		(41.46	%)
	2007		13.232		47,577		629,534		0.51	%		1.55	%		12.68	%
	2006		11.743		29,566		347,198		4.25	%		1.55	%		17.43	%
Spinnaker Choice with GMDB
	2009		10.211		565		5,793		1.44	%		1.75	%		32.58	%
	2008		7.702		561		4,332		0.47	%		1.75	%		(41.58	%)
	2007		13.184		558		7,372		0.39	%		1.75	%		12.45	%
	2006		11.725		555		6,514		1.18	%		1.75	%		17.25	%
AIM Small Cap Equity II
Spinnaker & Mainsail
	2009		8.459		5,936		50,207		0.18	%		1.40	%		19.22	%
	2008		7.095		1,409		9,999		0.00	%		1.40	%		(29.05	%)
Spinnaker Advisor
	2009		8.452		2,574		21,750		0.16	%		1.45	%		19.16	%
	2008		7.093		1,999		14,185		0.00	%		1.45	%		(29.07	%)
American Century Balanced
Spinnaker & Mainsail
	2009		12.004		773,356		9,283,947		5.29	%		1.40	%		13.87	%
	2008		10.542		849,896		8,959,478		2.71	%		1.40	%		(21.44	%)
	2007		13.419		992,055		13,312,206		2.09	%		1.40	%		3.47	%
	2006		12.969		1,085,757		14,081,101		1.96	%		1.40	%		8.10	%
	2005		11.997		1,198,113		14,373,763		1.80	%		1.40	%		3.48	%
Spinnaker Advisor
	2009		10.324		207,465		2,141,948		5.30	%		1.45	%		13.81	%
	2008		9.071		258,636		2,346,031		2.65	%		1.45	%		(21.48	%)
	2007		11.552		298,940		3,453,364		2.08	%		1.45	%		3.42	%
	2006		11.170		328,237		3,666,513		1.96	%		1.45	%		8.05	%
	2005		10.338		393,800		4,071,249		1.90	%		1.45	%		3.42	%
Spinnaker with EEB
	2009		11.903		456		5,424		4.97	%		1.55	%		13.71	%
	2008		10.468		334		3,496		2.13	%		1.55	%		(21.56	%)
	2007		13.345		195		2,595		1.36	%		1.55	%		3.31	%
	2006		12.917		68		872		0.00	%		1.55	%		29.17	%
Spinnaker with GMDB
	2009		11.869		29		332		5.45	%		1.60	%		13.64	%
	2008		10.444		32		326		2.70	%		1.60	%		(21.59	%)
	2007		13.320		36		480		2.23	%		1.60	%		3.26	%
	2006		12.900		39		505		0.38	%		1.60	%		7.89	%
	2005		11.957		6		71		0.00	%		1.60	%		3.27	%
Spinnaker Choice
	2009		11.084		5,130		56,864		5.06	%		1.55	%		13.71	%
	2008		9.748		6,257		60,994		2.86	%		1.55	%		(21.56	%)
	2007		12.427		6,479		80,517		2.22	%		1.55	%		3.31	%
	2006		12.028		13,779		165,743		0.79	%		1.55	%		7.93	%
	2005		11.144		3,396		37,843		0.44	%		1.55	%		3.33	%
American Century Inflation Protection II
Spinnaker & Mainsail
	2009		11.346		313,107		3,552,041		1.81	%		1.40	%		8.71	%
	2008		10.437		287,847		3,003,933		4.68	%		1.40	%		(2.97	%)
	2007		10.756		206,078		2,216,244		4.35	%		1.40	%		8.00	%
	2006		9.959		103,527		1,031,051		3.41	%		1.40	%		0.16	%
	2005		9.943		82,304		818,340		3.53	%		1.40	%		0.33	%

139

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
American Century Inflation Protection II (Continued)
Spinnaker Advisor
	2009	$	11.320		103,955	$	1,176,390		1.77	%		1.45	%		8.67	%
	2008		10.417		102,959		1,072,338		4.85	%		1.45	%		(3.03	%)
	2007		10.742		118,553		1,273,170		4.50	%		1.45	%		7.95	%
	2006		9.951		102,759		1,022,533		3.36	%		1.45	%		0.11	%
	2005		9.940		69,851		694,282		3.67	%		1.45	%		0.36	%
Spinnaker Choice
	2009		11.267		5,207		58,657		1.75	%		1.55	%		8.56	%
	2008		10.379		5,226		54,238		4.73	%		1.55	%		(3.12	%)
	2007		10.713		4,020		43,069		3.43	%		1.55	%		7.84	%
	2006		9.934		961		9,547		3.64	%		1.55	%		0.01	%
	2005		9.933		2,882		28,624		3.93	%		1.55	%		0.43	%
Spinnaker Choice with GMDB
	2009		11.162		-		-		0.38	%		1.75	%		8.34	%
	2008		10.303		8		79		5.28	%		1.75	%		(3.31	%)
	2007		10.656		85		905		4.67	%		1.75	%		7.62	%
	2006		9.901		282		2,789		3.33	%		1.75	%		(0.18	%)
	2005		9.919		305		3,025		2.28	%		1.75	%		0.57	%
American Century International
Spinnaker & Mainsail
	2009		9.602		1,078,617		10,356,957		2.05	%		1.40	%		31.91	%
	2008		7.279		1,164,670		8,478,208		0.83	%		1.40	%		(45.59	%)
	2007		13.379		1,254,258		16,781,150		0.67	%		1.40	%		16.41	%
	2006		11.493		1,338,300		15,381,851		1.58	%		1.40	%		23.29	%
	2005		9.322		1,360,594		12,683,528		1.20	%		1.40	%		11.68	%
Spinnaker Advisor
	2009		7.755		137,958		1,069,940		2.16	%		1.45	%		31.84	%
	2008		5.882		155,256		913,298		0.79	%		1.45	%		(45.62	%)
	2007		10.817		176,335		1,907,441		0.63	%		1.45	%		16.35	%
	2006		9.297		168,186		1,563,664		1.45	%		1.45	%		23.24	%
	2005		7.544		126,550		954,749		1.27	%		1.45	%		11.63	%
Spinnaker with EEB
	2009		9.520		999		9,509		1.68	%		1.55	%		31.71	%
	2008		7.228		687		4,966		0.69	%		1.55	%		(45.68	%)
	2007		13.306		389		5,173		0.46	%		1.55	%		16.23	%
	2006		11.448		146		1,665		0.00	%		1.55	%		14.48	%
Spinnaker with GMDB
	2009		9.493		6		55		3.53	%		1.60	%		31.63	%
	2008		7.212		37		267		0.78	%		1.60	%		(45.70	%)
	2007		13.281		36		475		0.00	%		1.60	%		16.17	%
	2006		11.432		1		12		0.00	%		1.60	%		14.32	%
Spinnaker Choice
	2009		12.796		2,797		35,794		2.14	%		1.55	%		31.70	%
	2008		9.716		4,743		46,086		0.67	%		1.55	%		(45.67	%)
	2007		17.884		15,622		279,380		0.13	%		1.55	%		16.23	%
	2006		15.387		16,486		253,665		0.30	%		1.55	%		23.12	%
	2005		12.498		703		8,789		0.00	%		1.55	%		11.52	%
American Century Large Company Value II
Spinnaker & Mainsail
	2009		9.124		29,480		268,979		4.42	%		1.40	%		18.25	%
	2008		7.716		19,804		152,810		2.18	%		1.40	%		(38.29	%)
	2007		12.504		16,155		202,008		0.44	%		1.40	%		(2.73	%)
	2006		12.855		15,954		205,085		0.01	%		1.40	%		18.12	%
	2005		10.883		9,304		101,254		3.05	%		1.40	%		7.49	%

140

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
American Century Large Company Value II (Continued)
Spinnaker Advisor
	2009	$	9.103		12,930	$	117,700		5.93	%		1.45	%		18.19	%
	2008		7.702		23,911		184,164		2.36	%		1.45	%		(38.32	%)
	2007		12.488		31,993		399,518		0.53	%		1.45	%		(2.77	%)
	2006		12.844		27,796		357,012		0.01	%		1.45	%		18.06	%
	2005		10.879		5,442		59,206		2.52	%		1.45	%		7.45	%
Spinnaker with GMDB
	2009		9.039		134		1,184		5.06	%		1.60	%		18.00	%
	2008		7.660		129		972		2.11	%		1.60	%		(38.41	%)
	2007		12.437		125		1,545		0.50	%		1.60	%		(2.93	%)
	2006		12.812		26		338		0.00	%		1.60	%		28.12	%
Spinnaker Choice
	2009		9.060		9,044		81,939		5.05	%		1.55	%		18.06	%
	2008		7.674		9,449		72,507		0.00	%		1.55	%		(38.38	%)
	2007		12.454		-		-		0.00	%		1.55	%		(2.87	%)
American Century Ultra I
Spinnaker & Mainsail
	2009		11.325		33,967		384,689		0.28	%		1.40	%		32.61	%
	2008		8.540		32,973		281,597		0.00	%		1.40	%		(42.30	%)
	2007		14.800		53,466		791,279		0.00	%		1.40	%		19.33	%
	2006		12.403		50,768		629,663		0.00	%		1.40	%		(4.61	%)
	2005		13.003		34,098		443,386		0.00	%		1.40	%		0.75	%
Spinnaker Advisor
	2009		11.287		3,028		34,181		0.28	%		1.45	%		32.54	%
	2008		8.516		3,030		25,804		0.00	%		1.45	%		(42.32	%)
	2007		14.765		13,149		194,145		0.00	%		1.45	%		19.26	%
	2006		12.380		10,575		130,915		0.00	%		1.45	%		(4.67	%)
	2005		12.986		9,497		123,331		0.00	%		1.45	%		0.70	%
Spinnaker with EEB
	2009		11.229		195		2,188		0.24	%		1.55	%		32.42	%
	2008		8.480		138		1,164		0.00	%		1.55	%		(42.38	%)
	2007		14.718		79		1,158		0.00	%		1.55	%		19.14	%
	2006		12.353		28		349		0.00	%		1.55	%		23.53	%
Spinnaker Choice
	2009		9.266		187		1,728		0.28	%		1.55	%		32.41	%
	2008		6.998		187		1,307		0.00	%		1.55	%		(42.38	%)
	2007		12.146		210		2,540		0.00	%		1.55	%		19.15	%
	2006		10.194		968		9,863		0.00	%		1.55	%		4.76	%
	2005		10.703		268		2,871		0.00	%		1.55	%		0.59	%
Spinnaker Choice with GMDB
	2009		9.162		571		5,230		0.28	%		1.75	%		32.15	%
	2008		6.933		567		3,924		0.00	%		1.75	%		(42.50	%)
	2007		12.057		563		6,784		0.00	%		1.75	%		18.91	%
	2006		10.140		560		5,677		0.00	%		1.75	%		1.40	%
American Century Ultra II
Spinnaker & Mainsail
	2009		9.251		11,801		109,160		0.17	%		1.40	%		32.65	%
	2008		6.974		10,560		73,634		0.00	%		1.40	%		(42.46	%)
	2007		12.120		7,822		94,807		0.00	%		1.40	%		21.20	%
Spinnaker Advisor
	2009		9.238		510		4,719		0.17	%		1.45	%		32.58	%
	2008		6.968		498		3,473		0.00	%		1.45	%		(42.48	%)
	2007		12.115		823		9,972		0.00	%		1.45	%		21.15	%

141

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
American Century Value
Spinnaker & Mainsail
	2009	$	12.065		294,076	$	3,548,099		5.49	%		1.40	%		18.20	%
	2008		10.207		278,747		2,845,379		2.46	%		1.40	%		(27.80	%)
	2007		14.137		298,666		4,222,312		1.57	%		1.40	%		(6.46	%)
	2006		15.114		283,849		4,290,154		1.31	%		1.40	%		17.01	%
	2005		12.917		262,245		3,387,395		0.72	%		1.40	%		3.58	%
Spinnaker Advisor
	2009		12.019		26,662		320,448		5.36	%		1.45	%		18.15	%
	2008		10.173		23,087		234,883		2.56	%		1.45	%		(27.84	%)
	2007		14.097		27,203		383,469		1.61	%		1.45	%		(6.51	%)
	2006		15.079		34,921		526,568		1.39	%		1.45	%		16.95	%
	2005		12.893		41,673		537,294		0.86	%		1.45	%		3.52	%
Spinnaker Choice
	2009		10.485		1,047		10,982		5.51	%		1.55	%		18.02	%
	2008		8.884		922		8,193		2.15	%		1.55	%		(27.91	%)
	2007		12.323		2,158		26,604		1.41	%		1.55	%		(6.60	%)
	2006		13.194		1,323		17,461		0.84	%		1.55	%		16.83	%
	2005		11.293		319		3,607		0.00	%		1.55	%		3.43	%
Dreyfus Appreciation
Spinnaker & Mainsail
	2009		9.369		380,664		3,566,623		2.60	%		1.40	%		20.86	%
	2008		7.752		414,103		3,210,400		2.05	%		1.40	%		(30.54	%)
	2007		11.160		495,944		5,534,698		1.61	%		1.40	%		5.64	%
	2006		10.564		588,189		6,213,951		1.62	%		1.40	%		14.86	%
	2005		9.197		688,026		6,328,006		0.02	%		1.40	%		2.93	%
Spinnaker Advisor
	2009		8.933		107,809		963,418		2.69	%		1.45	%		20.80	%
	2008		7.395		116,735		863,568		1.93	%		1.45	%		(30.56	%)
	2007		10.650		126,059		1,342,571		1.62	%		1.45	%		5.58	%
	2006		10.087		156,758		1,581,263		1.62	%		1.45	%		14.81	%
	2005		8.786		207,393		1,822,225		0.02	%		1.45	%		2.88	%
Spinnaker with GMDB
	2009		9.263		223		2,000		2.58	%		1.60	%		20.61	%
	2008		7.680		223		1,691		2.14	%		1.60	%		(30.67	%)
	2007		11.078		151		1,655		1.65	%		1.60	%		5.42	%
	2006		10.508		79		826		0.00	%		1.60	%		5.08	%
Spinnaker Choice
	2009		10.707		1,716		18,402		2.58	%		1.55	%		20.67	%
	2008		8.873		1,716		15,243		1.98	%		1.55	%		(30.63	%)
	2007		12.791		1,716		21,960		1.52	%		1.55	%		5.47	%
	2006		12.127		1,716		20,812		1.51	%		1.55	%		14.69	%
	2005		10.574		1,372		14,504		0.01	%		1.55	%		2.78	%
Dreyfus Midcap Stock
Spinnaker & Mainsail
	2009		10.959		886,723		9,717,469		1.42	%		1.40	%		33.63	%
	2008		8.201		947,581		7,771,281		0.96	%		1.40	%		(41.25	%)
	2007		13.959		1,065,106		14,868,046		0.43	%		1.40	%		0.08	%
	2006		13.948		1,268,984		17,700,047		0.38	%		1.40	%		6.25	%
	2005		13.127		1,479,224		19,417,586		0.03	%		1.40	%		7.66	%
Spinnaker Advisor
	2009		10.127		254,419		2,576,591		1.47	%		1.45	%		33.57	%
	2008		7.582		296,901		2,251,300		0.98	%		1.45	%		(41.28	%)
	2007		12.913		373,569		4,823,844		0.43	%		1.45	%		0.03	%
	2006		12.909		508,133		6,559,563		0.38	%		1.45	%		6.20	%
	2005		12.155		632,585		7,689,094		0.03	%		1.45	%		7.60	%

142

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Dreyfus Midcap Stock (Continued)
Spinnaker with GMDB
	2009	$	10.835		30	$	301		1.61	%		1.60	%		33.35	%
	2008		8.125		35		278		0.99	%		1.60	%		(41.37	%)
	2007		13.857		35		474		0.40	%		1.60	%		(0.12	%)
	2006		13.874		35		478		0.00	%		1.60	%		6.05	%
	2005		13.083		5		65		0.00	%		1.60	%		7.44	%
Spinnaker Choice
	2009		10.105		3,359		33,942		1.56	%		1.55	%		33.43	%
	2008		7.573		4,065		30,784		0.95	%		1.55	%		(41.34	%)
	2007		12.910		4,117		53,157		0.40	%		1.55	%		(0.07	%)
	2006		12.919		5,112		66,050		0.45	%		1.55	%		6.09	%
	2005		12.177		9,369		114,088		0.00	%		1.55	%		7.49	%
Spinnaker Choice with GMDB
	2009		9.991		-		-		3.95	%		1.75	%		33.16	%
	2008		7.503		17		125		1.36	%		1.75	%		(41.46	%)
	2007		12.816		173		2,224		0.46	%		1.75	%		(0.27	%)
	2006		12.851		613		7,885		0.38	%		1.75	%		5.89	%
	2005		12.136		664		8,061		0.00	%		1.75	%		7.28	%
Dreyfus Quality Bond
Spinnaker & Mainsail
	2009		14.503		298,365		4,327,352		4.76	%		1.40	%		13.36	%
	2008		12.794		343,626		4,396,440		4.94	%		1.40	%		(5.52	%)
	2007		13.541		420,173		5,689,376		4.82	%		1.40	%		2.10	%
	2006		13.263		441,156		5,850,919		4.59	%		1.40	%		2.79	%
	2005		12.903		528,321		6,816,863		3.60	%		1.40	%		1.06	%
Spinnaker Advisor
	2009		14.014		85,399		1,196,759		4.78	%		1.45	%		13.31	%
	2008		12.368		113,613		1,405,205		4.93	%		1.45	%		(5.56	%)
	2007		13.096		149,624		1,959,552		4.87	%		1.45	%		2.04	%
	2006		12.834		203,984		2,617,952		4.61	%		1.45	%		2.74	%
	2005		12.492		293,870		3,671,049		3.59	%		1.45	%		1.01	%
Dreyfus Socially Responsible
Spinnaker & Mainsail
	2009		6.116		474,717		2,903,582		0.96	%		1.40	%		31.90	%
	2008		4.637		509,371		2,362,065		0.74	%		1.40	%		(35.34	%)
	2007		7.171		498,242		3,573,096		0.48	%		1.40	%		6.27	%
	2006		6.748		406,047		2,739,899		0.11	%		1.40	%		7.69	%
	2005		6.266		440,102		2,757,643		0.00	%		1.40	%		2.19	%
Spinnaker Advisor
	2009		5.750		71,740		412,528		0.95	%		1.45	%		31.82	%
	2008		4.362		56,124		244,814		0.76	%		1.45	%		(35.37	%)
	2007		6.749		46,314		312,587		0.54	%		1.45	%		6.23	%
	2006		6.353		54,491		346,219		0.11	%		1.45	%		7.62	%
	2005		5.903		74,955		442,446		0.00	%		1.45	%		2.13	%
Spinnaker Choice
	2009		10.374		1,709		17,729		0.93	%		1.55	%		31.70	%
	2008		7.877		1,525		12,018		0.49	%		1.55	%		(35.43	%)
	2007		12.200		2,891		35,273		0.31	%		1.55	%		6.12	%
	2006		11.496		1,714		19,700		0.05	%		1.55	%		14.96	%

143

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Dreyfus Stock Index
Spinnaker & Mainsail
	2009	$	12.270		864,042	$	10,602,459		1.83	%		1.40	%		24.29	%
	2008		9.872		887,114		8,757,992		1.81	%		1.40	%		(38.20	%)
	2007		15.973		860,903		13,751,204		1.50	%		1.40	%		3.53	%
	2006		15.429		772,261		11,915,429		1.47	%		1.40	%		13.61	%
	2005		13.581		611,054		8,298,609		1.44	%		1.40	%		2.99	%
Spinnaker Advisor
	2009		12.230		290,567		3,553,621		1.87	%		1.45	%		24.24	%
	2008		9.844		307,102		3,023,293		1.72	%		1.45	%		(38.23	%)
	2007		15.936		377,748		6,019,712		1.47	%		1.45	%		3.48	%
	2006		15.401		377,730		5,817,440		1.41	%		1.45	%		13.55	%
	2005		13.563		417,403		5,661,100		1.41	%		1.45	%		2.94	%
Spinnaker with EEB
	2009		12.166		637		7,721		1.89	%		1.55	%		24.10	%
	2008		9.803		441		4,304		1.97	%		1.55	%		(38.29	%)
	2007		15.885		245		3,881		1.63	%		1.55	%		3.37	%
	2006		15.367		87		1,337		2.57	%		1.55	%		53.67	%
Spinnaker with GMDB
	2009		12.132		182		2,162		1.90	%		1.60	%		24.05	%
	2008		9.780		125		1,215		1.95	%		1.60	%		(38.32	%)
	2007		15.856		76		1,194		1.47	%		1.60	%		3.32	%
	2006		15.347		11		168		1.80	%		1.60	%		13.14	%
	2005		13.565		7		93		2.43	%		1.60	%		2.78	%
Spinnaker Choice
	2009		10.030		7,881		79,039		1.77	%		1.55	%		24.10	%
	2008		8.082		11,746		94,931		1.76	%		1.55	%		(38.29	%)
	2007		13.096		14,705		192,575		1.44	%		1.55	%		3.37	%
	2006		12.669		16,795		212,775		1.43	%		1.55	%		13.44	%
	2005		11.168		18,465		206,214		2.16	%		1.55	%		2.84	%
Spinnaker Choice with GMDB
	2009		9.917		487		4,826		1.84	%		1.75	%		23.85	%
	2008		8.007		479		3,842		1.67	%		1.75	%		(38.41	%)
	2007		13.000		749		9,752		1.48	%		1.75	%		3.16	%
	2006		12.602		1,082		13,639		1.40	%		1.75	%		13.22	%
	2005		11.131		1,172		13,048		28.57	%		1.75	%		2.63	%
Dreyfus Technology Growth
Spinnaker & Mainsail
	2009		4.065		586,599		2,384,397		0.45	%		1.40	%		55.51	%
	2008		2.614		676,538		1,768,722		0.00	%		1.40	%		(42.01	%)
	2007		4.508		705,016		3,177,969		0.00	%		1.40	%		13.13	%
	2006		3.985		740,251		2,949,733		0.00	%		1.40	%		2.87	%
	2005		3.874		842,303		3,262,863		0.00	%		1.40	%		2.35	%
Spinnaker Advisor
	2009		3.683		195,329		719,415		0.40	%		1.45	%		55.40	%
	2008		2.370		162,127		384,254		0.00	%		1.45	%		(42.03	%)
	2007		4.088		172,694		706,063		0.00	%		1.45	%		13.05	%
	2006		3.616		140,847		509,317		0.00	%		1.45	%		2.81	%
	2005		3.517		161,952		569,601		0.00	%		1.45	%		2.30	%

144

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
DWS Balanced VIP A
Spinnaker & Mainsail
	2009	$	21.475		526,299	$	11,302,343		3.80	%		1.40	%		21.72	%
	2008		17.643		604,845		10,671,728		4.11	%		1.40	%		(28.34	%)
	2007		24.622		711,397		17,516,272		3.33	%		1.40	%		3.38	%
	2006		23.818		859,775		20,478,148		2.59	%		1.40	%		8.71	%
	2005		21.909		1,050,813		23,021,845		3.15	%		1.40	%		2.68	%
Spinnaker Advisor
	2009		8.944		135,687		1,213,625		4.23	%		1.45	%		21.65	%
	2008		7.352		180,353		1,325,993		3.97	%		1.45	%		(28.38	%)
	2007		10.265		188,337		1,933,365		3.39	%		1.45	%		3.32	%
	2006		9.935		240,085		2,385,261		2.61	%		1.45	%		8.66	%
	2005		9.143		291,089		2,661,468		3.09	%		1.45	%		2.63	%
DWS Capital Growth VIP B
Spinnaker & Mainsail
	2009		8.435		158,352		1,335,761		0.82	%		1.40	%		24.72	%
	2008		6.763		66,500		449,743		0.00	%		1.40	%		(32.37	%)
Spinnaker Advisor
	2009		8.428		21,689		182,803		0.08	%		1.45	%		24.66	%
	2008		6.761		635		4,294		0.00	%		1.45	%		(32.39	%)
DWS Global Opportunities B Share
Spinnaker & Mainsail
	2009		7.700		5,398		41,569		0.58	%		1.40	%		45.61	%
	2008		5.288		6		33		0.00	%		1.40	%		(47.12	%)
Spinnaker Advisor
	2009		7.694		2,032		15,627		0.00	%		1.45	%		45.53	%
	2008		5.287		-		-		0.00	%		1.45	%		(47.13	%)
DWS Global Thematic B Share
Spinnaker & Mainsail
	2009		7.523		3,975		29,906		0.50	%		1.40	%		41.25	%
	2008		5.326		606		3,228		0.00	%		1.40	%		(46.74	%)
DWS International VIP A
Spinnaker & Mainsail
	2009		16.531		278,102		4,597,309		4.41	%		1.40	%		31.67	%
	2008		12.555		314,108		3,943,814		1.41	%		1.40	%		(48.94	%)
	2007		24.587		359,829		8,847,083		2.47	%		1.40	%		12.99	%
	2006		21.761		428,469		9,323,933		1.89	%		1.40	%		24.16	%
	2005		17.526		505,855		8,865,389		1.63	%		1.40	%		14.56	%
Spinnaker Advisor
	2009		7.763		8,783		68,184		3.62	%		1.45	%		31.60	%
	2008		5.899		18,104		106,801		1.46	%		1.45	%		(48.96	%)
	2007		11.558		36,168		418,020		2.35	%		1.45	%		12.93	%
	2006		10.234		39,250		401,701		1.99	%		1.45	%		24.09	%
	2005		8.247		47,003		387,616		1.76	%		1.45	%		14.51	%
DWS Small Cap Index A Share
Focus Tier I
	2009		8.711		713		6,215		0.00	%		1.30	%		24.87	%
	2008		6.976		-		-		0.00	%		1.30	%		(30.24	%)
Focus Tier II
	2009		8.718		5,148		44,877		1.21	%		1.30	%		24.94	%
	2008		6.978		1,958		13,666		0.00	%		1.30	%		(30.22	%)
Focus Tier II with GMDB
	2009		8.704		870		7,574		0.00	%		1.30	%		24.82	%
	2008		6.973		-		-		0.00	%		1.30	%		(30.27	%)

145

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Federated Capital Income
Spinnaker & Mainsail
	2009	$	15.345		102,348	$	1,570,918		6.32	%		1.40	%		26.49	%
	2008		12.131		128,347		1,557,293		6.12	%		1.40	%		(21.49	%)
	2007		15.451		159,479		2,464,211		5.10	%		1.40	%		2.58	%
	2006		15.062		182,071		2,742,438		5.93	%		1.40	%		14.04	%
	2005		13.208		217,177		2,868,486		5.37	%		1.40	%		4.81	%
Spinnaker Advisor
	2009		9.148		5,069		46,375		6.30	%		1.45	%		26.44	%
	2008		7.235		5,966		43,165		6.01	%		1.45	%		(21.53	%)
	2007		9.220		8,314		76,663		5.58	%		1.45	%		2.53	%
	2006		8.993		15,500		139,390		6.21	%		1.45	%		13.99	%
	2005		7.889		17,698		139,624		5.08	%		1.45	%		4.75	%
Spinnaker Choice
	2009		13.179		1,838		24,229		6.03	%		1.55	%		26.31	%
	2008		10.434		1,847		19,273		5.68	%		1.55	%		(21.61	%)
	2007		13.310		1,854		24,673		4.93	%		1.55	%		2.43	%
	2006		12.994		1,859		24,157		5.72	%		1.55	%		13.86	%
	2005		11.412		1,467		16,739		1.67	%		1.55	%		4.66	%
Federated High Income Bond
Spinnaker & Mainsail
	2009		18.257		155,879		2,846,101		11.35	%		1.40	%		50.72	%
	2008		12.113		176,828		2,142,003		10.17	%		1.40	%		(27.02	%)
	2007		16.598		224,049		3,718,880		8.04	%		1.40	%		1.98	%
	2006		16.276		265,091		4,314,544		9.01	%		1.40	%		9.27	%
	2005		14.895		330,080		4,916,510		8.68	%		1.40	%		1.24	%
Spinnaker Advisor
	2009		14.935		34,396		513,827		11.99	%		1.45	%		50.66	%
	2008		9.913		45,688		453,018		10.82	%		1.45	%		(27.06	%)
	2007		13.591		72,238		981,815		8.07	%		1.45	%		1.93	%
	2006		13.334		87,156		1,162,120		8.77	%		1.45	%		9.21	%
	2005		12.209		142,890		1,744,488		8.82	%		1.45	%		1.19	%
Spinnaker Choice
	2009		13.185		973		12,831		10.97	%		1.55	%		50.50	%
	2008		8.761		2,633		23,070		9.72	%		1.55	%		(27.13	%)
	2007		12.023		2,507		30,130		7.75	%		1.55	%		1.83	%
	2006		11.807		2,476		29,231		8.80	%		1.55	%		9.11	%
	2005		10.821		1,043		11,289		0.00	%		1.55	%		1.07	%
Federated International Equity
Spinnaker & Mainsail
	2009		16.282		60,674		987,910		2.95	%		1.40	%		39.29	%
	2008		11.689		75,649		884,311		0.66	%		1.40	%		(46.48	%)
	2007		21.841		95,325		2,081,966		0.18	%		1.40	%		8.02	%
	2006		20.220		119,017		2,406,534		0.20	%		1.40	%		17.24	%
	2005		17.246		148,903		2,568,030		0.00	%		1.40	%		7.57	%
Fidelity Asset Manager
Spinnaker & Mainsail
	2009		12.871		27,851		358,474		2.48	%		1.40	%		27.32	%
	2008		10.109		27,715		280,173		2.78	%		1.40	%		(29.71	%)
	2007		14.382		25,325		364,221		5.88	%		1.40	%		13.89	%
	2006		12.628		29,800		376,316		2.91	%		1.40	%		5.83	%
	2005		11.933		35,420		422,650		2.25	%		1.40	%		2.61	%

146

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Fidelity Asset Manager (Continued)
Spinnaker Advisor
	2009	$	12.828		9,158	$	117,479		2.35	%		1.45	%		27.25	%
	2008		10.081		11,889		119,853		2.68	%		1.45	%		(29.74	%)
	2007		14.349		7,925		113,726		5.84	%		1.45	%		13.84	%
	2006		12.605		9,952		125,451		2.68	%		1.45	%		5.77	%
	2005		11.917		10,439		124,402		2.35	%		1.45	%		2.56	%
Fidelity Contrafund
Spinnaker & Mainsail
	2009		15.922		1,687,798		26,874,394		1.44	%		1.40	%		33.82	%
	2008		11.898		1,673,409		19,910,794		0.99	%		1.40	%		(43.32	%)
	2007		20.990		1,745,798		36,644,384		0.93	%		1.40	%		15.95	%
	2006		18.103		1,906,667		34,515,973		1.30	%		1.40	%		10.17	%
	2005		16.432		1,961,581		32,232,130		0.28	%		1.40	%		15.32	%
Spinnaker Advisor
	2009		15.733		135,376		2,129,887		1.56	%		1.45	%		33.76	%
	2008		11.762		120,203		1,413,902		1.06	%		1.45	%		(43.35	%)
	2007		20.761		108,108		2,244,426		0.95	%		1.45	%		15.89	%
	2006		17.914		108,759		1,948,330		1.33	%		1.45	%		10.11	%
	2005		16.269		95,238		1,549,400		0.14	%		1.45	%		15.26	%
Spinnaker with GMDB
	2009		15.743		197		3,087		1.33	%		1.60	%		33.56	%
	2008		11.787		243		2,854		1.06	%		1.60	%		(43.43	%)
	2007		20.836		202		4,205		1.24	%		1.60	%		15.72	%
	2006		18.006		95		1,715		1.47	%		1.60	%		80.06	%
Spinnaker Choice
	2009		12.317		19,201		236,507		1.46	%		1.55	%		33.62	%
	2008		9.218		16,181		149,163		0.85	%		1.55	%		(43.40	%)
	2007		16.286		21,140		344,283		1.53	%		1.55	%		15.77	%
	2006		14.067		11,301		158,968		1.31	%		1.55	%		10.00	%
	2005		12.788		1,286		16,446		0.00	%		1.55	%		15.14	%
Spinnaker Choice with GMDB
	2009		12.178		301		3,650		1.45	%		1.75	%		33.36	%
	2008		9.132		298		2,715		1.04	%		1.75	%		(43.51	%)
	2007		16.167		281		4,537		0.88	%		1.75	%		15.54	%
Fidelity Equity Income
Spinnaker & Mainsail
	2009		12.453		582,965		7,259,933		2.35	%		1.40	%		28.39	%
	2008		9.699		579,160		5,617,326		2.58	%		1.40	%		(43.45	%)
	2007		17.152		567,663		9,736,689		1.74	%		1.40	%		0.11	%
	2006		17.133		567,597		9,724,716		3.36	%		1.40	%		18.53	%
	2005		14.455		503,322		7,275,366		1.42	%		1.40	%		4.40	%
Spinnaker Advisor
	2009		12.412		75,810		940,964		2.32	%		1.45	%		28.34	%
	2008		9.671		74,860		724,024		2.25	%		1.45	%		(43.48	%)
	2007		17.112		92,432		1,581,722		1.57	%		1.45	%		0.06	%
	2006		17.101		113,236		1,936,542		3.48	%		1.45	%		18.47	%
	2005		14.435		90,145		1,301,272		1.08	%		1.45	%		4.34	%
Spinnaker with EEB
	2009		12.348		284		3,495		2.60	%		1.55	%		28.21	%
	2008		9.631		192		1,844		3.56	%		1.55	%		(43.54	%)
	2007		17.058		103		1,753		2.63	%		1.55	%		(0.04	%)
	2006		17.064		37		629		7.86	%		1.55	%		70.64	%

147

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Fidelity Equity Income (Continued)
Spinnaker with GMDB
	2009	$	12.313		19	$	205		2.41	%		1.60	%		28.14	%
	2008		9.609		17		162		3.22	%		1.60	%		(43.56	%)
	2007		17.026		12		202		2.28	%		1.60	%		(0.09	%)
	2006		17.042		8		135		3.21	%		1.60	%		18.30	%
	2005		14.406		5		79		0.00	%		1.60	%		4.19	%
Spinnaker Choice
	2009		9.796		4,708		46,121		2.21	%		1.55	%		28.20	%
	2008		7.641		5,300		40,494		2.56	%		1.55	%		(43.53	%)
	2007		13.532		4,982		67,426		1.28	%		1.55	%		(0.04	%)
	2006		13.538		8,151		110,344		3.15	%		1.55	%		18.35	%
	2005		11.439		10,588		121,111		0.00	%		1.55	%		4.25	%
Spinnaker Choice with GMDB
	2009		9.685		-		-		0.35	%		1.75	%		27.96	%
	2008		7.569		21		158		0.45	%		1.75	%		(43.65	%)
	2007		13.433		208		2,806		0.78	%		1.75	%		(0.24	%)
	2006		13.466		815		10,976		3.29	%		1.75	%		18.12	%
	2005		11.400		883		10,066		0.00	%		1.75	%		4.04	%
Fidelity Freedom Funds 2010 II
Spinnaker & Mainsail
	2009		9.276		5,611		52,054		4.16	%		1.40	%		22.23	%
	2008		7.589		2,395		18,176		7.05	%		1.40	%		(24.11	%)
Spinnaker Advisor
	2009		9.269		5,109		47,358		4.27	%		1.45	%		22.17	%
	2008		7.587		4,090		31,029		2.90	%		1.45	%		(24.13	%)
Fidelity Freedom Funds 2015 II
Spinnaker & Mainsail
	2009		9.136		5,681		51,906		4.67	%		1.40	%		23.28	%
	2008		7.411		1,194		8,851		3.10	%		1.40	%		(25.89	%)
Spinnaker Advisor
	2009		9.129		1,559		14,229		4.16	%		1.45	%		23.23	%
	2008		7.408		1,008		7,470		3.23	%		1.45	%		(25.92	%)
Fidelity Freedom Funds 2020 II
Spinnaker & Mainsail
	2009		8.760		59,721		523,163		3.31	%		1.40	%		26.75	%
	2008		6.911		57,127		394,791		7.06	%		1.40	%		(30.89	%)
Spinnaker Advisor
	2009		8.753		1,056		9,240		3.07	%		1.45	%		26.71	%
	2008		6.908		-		-		0.00	%		1.45	%		(30.92	%)
Fidelity Freedom Funds 2025 II
Spinnaker & Mainsail
	2009		8.658		14,309		123,883		4.70	%		1.40	%		28.00	%
	2008		6.764		-		-		0.00	%		1.40	%		(32.36	%)
Spinnaker Advisor
	2009		8.650		14,314		123,826		3.60	%		1.45	%		27.92	%
	2008		6.762		3,160		21,368		2.64	%		1.45	%		(32.38	%)
Fidelity Freedom Funds 2030 II
Spinnaker & Mainsail
	2009		8.302		10,484		87,046		3.48	%		1.40	%		29.35	%
	2008		6.418		9,793		62,856		2.56	%		1.40	%		35.82	%
Spinnaker Advisor
	2009		8.295		5,910		49,024		2.45	%		1.45	%		29.29	%
	2008		6.416		-		-		0.00	%		1.45	%		(35.84	%)

148

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Fidelity Freedom Income Fund II
Spinnaker & Mainsail
	2009	$	10.036		4,856	$	48,742		3.31	%		1.40	%		13.04	%
	2008		8.878		5,249		46,604		3.62	%		1.40	%		11.22	%
Spinnaker Advisor
	2009		10.028		383		3,839		6.48	%		1.45	%		12.99	%
	2008		8.875		-		-		0.00	%		1.45	%		(11.25	%)
Fidelity Growth
Spinnaker & Mainsail
	2009		5.835		1,877,698		10,956,116		0.45	%		1.40	%		26.52	%
	2008		4.612		2,057,295		9,489,015		0.82	%		1.40	%		(47.90	%)
	2007		8.853		2,191,488		19,402,364		0.83	%		1.40	%		25.19	%
	2006		7.072		2,440,339		17,258,078		0.39	%		1.40	%		5.36	%
	2005		6.712		2,610,038		17,517,489		0.50	%		1.40	%		4.34	%
Spinnaker Advisor
	2009		5.515		285,036		1,571,989		0.44	%		1.45	%		26.43	%
	2008		4.362		319,895		1,395,314		0.76	%		1.45	%		(47.93	%)
	2007		8.377		366,331		3,068,635		0.86	%		1.45	%		25.14	%
	2006		6.694		479,926		3,212,845		0.40	%		1.45	%		5.32	%
	2005		6.356		547,916		3,482,799		0.51	%		1.45	%		4.27	%
Spinnaker with GMDB
	2009		5.769		405		2,289		0.46	%		1.60	%		26.26	%
	2008		4.569		409		1,855		0.84	%		1.60	%		(48.01	%)
	2007		8.789		412		3,615		0.82	%		1.60	%		24.95	%
	2006		7.034		416		2,925		0.39	%		1.60	%		5.16	%
	2005		6.689		421		2,816		0.49	%		1.60	%		4.13	%
Spinnaker Choice
	2009		9.295		914		8,477		0.37	%		1.55	%		26.31	%
	2008		7.359		1,363		10,020		0.88	%		1.55	%		(47.98	%)
	2007		14.146		1,285		18,166		0.97	%		1.55	%		25.00	%
	2006		11.317		1,772		20,059		0.48	%		1.55	%		5.22	%
	2005		10.756		4,372		47,026		0.00	%		1.55	%		4.17	%
Spinnaker Choice with GMDB
	2009		9.190		549		5,040		0.47	%		1.75	%		26.06	%
	2008		7.290		548		3,995		0.79	%		1.75	%		(48.09	%)
	2007		14.043		634		8,913		0.80	%		1.75	%		24.75	%
	2006		11.257		874		9,843		0.21	%		1.75	%		5.01	%
	2005		10.720		374		4,012		0.00	%		1.75	%		3.97	%
Fidelity Growth & Income
Spinnaker & Mainsail
	2009		8.772		639,690		5,611,489		1.11	%		1.40	%		25.44	%
	2008		6.993		686,874		4,803,529		1.22	%		1.40	%		(42.52	%)
	2007		12.165		703,862		8,562,476		1.84	%		1.40	%		10.56	%
	2006		11.003		721,884		7,943,075		0.89	%		1.40	%		11.60	%
	2005		9.859		786,236		7,751,213		1.52	%		1.40	%		6.15	%
Spinnaker Advisor
	2009		8.446		150,163		1,268,253		1.04	%		1.45	%		25.39	%
	2008		6.736		179,092		1,206,454		1.14	%		1.45	%		(42.55	%)
	2007		11.724		209,225		2,452,973		1.80	%		1.45	%		10.50	%
	2006		10.610		256,553		2,721,961		0.93	%		1.45	%		11.56	%
	2005		9.511		289,827		2,756,482		1.68	%		1.45	%		6.09	%
Spinnaker with GMDB
	2009		8.673		20		168		1.24	%		1.60	%		25.19	%
	2008		6.928		13		91		2.11	%		1.60	%		(42.63	%)
	2007		12.076		8		94		1.58	%		1.60	%		10.34	%
	2006		10.945		3		34		0.00	%		1.60	%		9.45	%

149

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Fidelity Growth & Income (Continued)
Spinnaker Choice
	2009	$	9.880		2,941	$	29,061		1.06	%		1.55	%		25.25	%
	2008		7.888		3,753		29,601		1.45	%		1.55	%		(42.60	%)
	2007		13.743		2,260		31,066		1.42	%		1.55	%		10.39	%
	2006		12.449		53		656		0.51	%		1.55	%		11.44	%
	2005		11.171		14		152		0.00	%		1.55	%		5.99	%
Fidelity Growth Opportunities
Spinnaker & Mainsail
	2009		7.203		404,328		2,912,483		0.47	%		1.40	%		43.83	%
	2008		5.008		444,895		2,228,201		0.39	%		1.40	%		(55.65	%)
	2007		11.291		520,527		5,877,466		0.00	%		1.40	%		21.46	%
	2006		9.296		599,770		5,575,599		0.73	%		1.40	%		3.99	%
	2005		8.939		693,573		6,199,888		0.95	%		1.40	%		7.38	%
Spinnaker Advisor
	2009		6.401		24,991		159,990		0.49	%		1.45	%		43.75	%
	2008		4.453		24,656		109,803		0.36	%		1.45	%		(55.67	%)
	2007		10.045		29,369		295,019		0.00	%		1.45	%		21.40	%
	2006		8.274		42,482		351,501		0.68	%		1.45	%		3.94	%
	2005		7.960		49,201		391,648		1.04	%		1.45	%		7.32	%
Fidelity Index 500
Focus Tier I
	2009		7.429		14,631		108,651		2.83	%		1.35	%		24.90	%
	2008		5.948		11,830		70,333		3.93	%		1.35	%		(37.84	%)
	2007		9.569		2,650		25,322		1.37	%		1.35	%		(4.31	%)
Focus Tier II
	2009		7.439		10,756		79,995		2.83	%		1.30	%		24.98	%
	2008		5.952		7,137		42,455		2.63	%		1.30	%		(37.81	%)
	2007		9.571		1,858		17,769		0.82	%		1.30	%		(4.29	%)
Focus Tier I with GMDB
	2009		7.410		-		-		0.66	%		1.45	%		24.79	%
	2008		5.938		19,718		117,079		2.53	%		1.45	%		(37.91	%)
	2007		9.563		-		-		0.00	%		1.45	%		(4.37	%)
Focus Tier II with GMDB
	2009		7.419		19,698		146,100		2.14	%		1.40	%		24.84	%
	2008		5.943		-		-		0.00	%		1.40	%		(37.87	%)
	2007		9.566		-		-		0.00	%		1.40	%		(4.34	%)
Fidelity Mid-Cap Advisor II
Spinnaker & Mainsail
	2009		12.604		505,863		6,376,168		0.47	%		1.40	%		37.81	%
	2008		9.146		483,002		4,417,684		0.24	%		1.40	%		(40.45	%)
	2007		15.358		380,222		5,839,585		0.50	%		1.40	%		13.72	%
	2006		13.505		273,628		3,695,256		0.09	%		1.40	%		10.85	%
	2005		12.183		53,498		651,791		0.00	%		1.40	%		21.27	%
Spinnaker Advisor
	2009		12.575		113,732		1,430,185		0.48	%		1.45	%		37.75	%
	2008		9.129		105,314		961,462		0.23	%		1.45	%		(40.48	%)
	2007		15.338		98,538		1,511,367		0.51	%		1.45	%		13.67	%
	2006		13.493		58,874		794,403		0.07	%		1.45	%		10.79	%
	2005		12.179		7,738		94,247		0.00	%		1.45	%		21.23	%
Spinnaker with GMDB
	2009		12.487		84		996		0.50	%		1.60	%		37.54	%
	2008		9.079		73		657		0.23	%		1.60	%		(40.57	%)
	2007		15.276		65		985		0.44	%		1.60	%		13.49	%
	2006		13.460		58		774		0.00	%		1.60	%		34.60	%

150

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Fidelity Mid-Cap Advisor II (Continued)
Spinnaker Choice
	2009	$	12.516		5,370	$	67,209		0.45	%		1.55	%		37.60	%
	2008		9.096		6,358		57,831		0.25	%		1.55	%		(40.54	%)
	2007		15.297		5,860		89,638		0.51	%		1.55	%		13.56	%
	2006		13.471		5,752		77,485		0.02	%		1.55	%		10.68	%
	2005		12.171		261		3,173		0.00	%		1.55	%		21.15	%
Fidelity Money Market Fund
Focus Tier I
	2009		10.318		142,108		1,466,211		0.76	%		1.35	%		(0.63	%)
	2008		10.383		48,309		501,576		2.83	%		1.35	%		1.64	%
	2007		10.215		28,263		288,708		2.19	%		1.35	%		2.15	%
Focus Tier II
	2009		10.331		38,846		401,297		0.79	%		1.30	%		(0.58	%)
	2008		10.391		43,178		448,652		2.99	%		1.30	%		1.69	%
	2007		10.218		28,255		288,703		2.13	%		1.30	%		2.18	%
Focus Tier III
	2009		10.358		25,590		265,051		0.72	%		1.20	%		(0.48	%)
	2008		10.408		14,477		150,650		2.65	%		1.20	%		1.80	%
	2007		10.224		-		-		2.34	%		1.20	%		2.24	%
Focus Tier I with GMDB
	2009		10.291		10,047		103,398		0.62	%		1.45	%		(0.73	%)
	2008		10.367		5,570		57,743		2.79	%		1.45	%		1.55	%
	2007		10.209		7,898		80,623		0.18	%		1.45	%		2.09	%
Focus Tier II with GMDB
	2009		10.304		7,510		77,386		0.72	%		1.40	%		(0.68	%)
	2008		10.375		9,955		103,283		2.94	%		1.40	%		1.60	%
	2007		10.212		21,754		222,139		0.23	%		1.40	%		2.12	%
Fidelity Overseas II
Spinnaker & Mainsail
	2009		7.281		10,887		79,269		4.59	%		1.40	%		24.46	%
	2008		5.850		2,802		16,389		7.23	%		1.40	%		(41.50	%)
Spinnaker Advisor
	2009		7.275		3,830		27,870		2.07	%		1.45	%		24.40	%
	2008		5.848		5,051		29,541		3.06	%		1.45	%		(41.52	%)
Fidelity VIP Money Market Service Class
Spinnaker & Mainsail
	2009		10.866		868,587		9,437,656		0.42	%		1.40	%		(0.92	%)
	2008		10.967		561,227		6,154,660		2.67	%		1.40	%		1.34	%
	2007		10.822		307,919		3,332,080		4.81	%		1.40	%		3.49	%
	2006		10.457		161,990		1,693,935		4.59	%		1.40	%		3.17	%
	2005		10.136		152,317		1,543,951		2.93	%		1.40	%		1.34	%
Spinnaker Advisor
	2009		10.839		324,504		3,516,840		0.54	%		1.45	%		(0.97	%)
	2008		10.945		515,305		5,639,660		2.60	%		1.45	%		1.29	%
	2007		10.806		218,982		2,366,062		4.82	%		1.45	%		3.44	%
	2006		10.446		127,618		1,333,127		4.81	%		1.45	%		3.11	%
	2005		10.131		69,027		699,314		2.86	%		1.45	%		1.30	%
Spinnaker with EEB
	2009		10.784		172		1,860		0.24	%		1.55	%		(1.06	%)
	2008		10.900		-		-		0.00	%		1.55	%		1.19	%
	2007		10.772		-		-		0.00	%		1.55	%		3.33	%

151

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Fidelity VIP Money Market Service Class (Continued)
Spinnaker with GMDB
	2009	$	10.756		343	$	3,688		0.40	%		1.60	%		(1.12	%)
	2008		10.878		211		2,295		2.73	%		1.60	%		1.13	%
	2007		10.756		214		2,300		4.95	%		1.60	%		3.28	%
	2006		10.414		806		8,396		4.37	%		1.60	%		2.96	%
	2005		10.115		220		2,221		2.93	%		1.60	%		1.15	%
Spinnaker Choice
	2009		10.784		12,653		136,516		0.50	%		1.55	%		(1.06	%)
	2008		10.900		13,378		145,819		2.69	%		1.55	%		1.19	%
	2007		10.772		3,788		40,817		4.74	%		1.55	%		3.33	%
	2006		10.425		2,560		26,677		5.27	%		1.55	%		3.01	%
	2005		10.120		2,059		20,841		2.82	%		1.55	%		1.20	%
Franklin Flex Cap Growth Securities
Spinnaker & Mainsail
	2009		10.996		23,397		257,262		0.00	%		1.40	%		31.12	%
	2008		8.386		15,024		125,990		0.11	%		1.40	%		(36.21	%)
	2007		13.147		11,218		147,483		0.13	%		1.40	%		12.73	%
	2006		11.663		10,031		116,989		0.01	%		1.40	%		3.74	%
	2005		11.242		12,906		145,084		0.26	%		1.40	%		11.71	%
Spinnaker Advisor
	2009		10.970		256		2,817		0.00	%		1.45	%		31.06	%
	2008		8.370		2,532		21,198		0.11	%		1.45	%		(36.25	%)
	2007		13.129		2,531		33,228		0.00	%		1.45	%		12.67	%
Spinnaker Choice
	2009		10.919		133		1,436		0.00	%		1.55	%		30.92	%
	2008		8.340		135		1,121		0.14	%		1.55	%		(36.31	%)
	2007		13.094		5,264		68,920		0.01	%		1.55	%		12.55	%
Spinnaker Choice with GMDB
	2009		10.817		339		3,652		0.00	%		1.75	%		30.66	%
	2008		8.279		325		2,682		0.10	%		1.75	%		(36.43	%)
	2007		13.024		345		4,488		0.00	%		1.75	%		12.32	%
Franklin Founding Allocation Fund Class II
Spinnaker & Mainsail
	2009		8.545		37,126		317,255		3.55	%		1.40	%		28.44	%
	2008		6.653		16,627		110,624		4.50	%		1.40	%		(33.47	%)
Spinnaker Advisor
	2009		8.538		5,109		43,624		2.65	%		1.45	%		28.37	%
	2008		6.651		7,095		47,193		2.34	%		1.45	%		(33.49	%)
Franklin Income Securities Fund Class II
Spinnaker & Mainsail
	2009		11.371		453,416		5,155,877		8.16	%		1.40	%		33.71	%
	2008		8.504		455,019		3,869,594		5.53	%		1.40	%		(30.64	%)
	2007		12.260		423,710		5,194,721		3.22	%		1.40	%		2.31	%
	2006		11.984		256,378		3,072,359		3.31	%		1.40	%		16.61	%
	2005		10.277		159,231		1,636,479		3.91	%		1.40	%		0.19	%
Spinnaker Advisor
	2009		11.342		77,933		883,943		9.53	%		1.45	%		33.64	%
	2008		8.487		121,665		1,032,563		5.45	%		1.45	%		(30.67	%)
	2007		12.241		135,919		1,663,823		3.17	%		1.45	%		2.25	%
	2006		11.971		73,472		879,561		3.39	%		1.45	%		16.54	%
	2005		10.272		37,114		381,227		4.03	%		1.45	%		0.15	%

152

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Franklin Income Securities Fund Class II (Continued)
Spinnaker with GMDB
	2009	$	11.256		751	$	8,444		8.74	%		1.60	%		33.44	%
	2008		8.435		879		7,416		5.38	%		1.60	%		(30.78	%)
	2007		12.185		883		10,769		3.31	%		1.60	%		2.10	%
	2006		11.934		678		8,092		3.65	%		1.60	%		16.37	%
	2005		10.255		650		6,666		6.10	%		1.60	%		(0.01	%)
Spinnaker Choice
	2009		11.285		8,234		92,929		11.54	%		1.55	%		33.52	%
	2008		8.452		33,208		280,687		5.37	%		1.55	%		(30.74	%)
	2007		12.204		37,234		454,394		3.66	%		1.55	%		2.16	%
	2006		11.946		28,456		339,950		4.08	%		1.55	%		16.42	%
	2005		10.261		10,248		105,156		1.57	%		1.55	%		0.05	%
Spinnaker Choice with GMDB
	2009		11.171		1,033		11,532		8.15	%		1.75	%		33.24	%
	2008		8.384		1,055		8,845		5.41	%		1.75	%		(30.88	%)
	2007		12.129		1,110		13,456		3.16	%		1.75	%		1.95	%
	2006		11.897		615		7,318		3.58	%		1.75	%		16.19	%
	2005		10.239		618		6,328		0.00	%		1.75	%		(0.15	%)
Franklin Small Cap Value Fund II
Spinnaker & Mainsail
	2009		10.664		476,485		5,081,373		1.78	%		1.40	%		27.36	%
	2008		8.373		353,128		2,956,856		1.14	%		1.40	%		(33.95	%)
	2007		12.677		269,814		3,420,466		0.56	%		1.40	%		(3.74	%)
	2006		13.170		190,410		2,507,738		0.60	%		1.40	%		15.35	%
	2005		11.417		49,903		569,725		0.56	%		1.40	%		13.48	%
Spinnaker Advisor
	2009		10.639		100,707		1,071,257		1.71	%		1.45	%		27.29	%
	2008		8.358		67,599		564,837		1.19	%		1.45	%		(33.98	%)
	2007		12.660		63,775		807,397		0.64	%		1.45	%		(3.79	%)
	2006		13.159		47,880		630,058		0.51	%		1.45	%		15.30	%
	2005		11.413		37,422		427,093		0.40	%		1.45	%		13.44	%
Spinnaker with GMDB
	2009		10.565		236		2,467		1.64	%		1.60	%		27.11	%
	2008		8.312		231		1,909		1.21	%		1.60	%		(34.08	%)
	2007		12.609		167		2,079		0.68	%		1.60	%		(3.94	%)
	2006		13.126		81		1,057		1.01	%		1.60	%		31.26	%
Spinnaker Choice
	2009		10.590		3,170		33,567		1.76	%		1.55	%		27.18	%
	2008		8.327		2,250		18,739		1.38	%		1.55	%		(34.05	%)
	2007		12.626		4,048		51,108		0.55	%		1.55	%		(3.89	%)
	2006		13.137		11,324		148,765		0.45	%		1.55	%		15.19	%
	2005		11.405		4,324		49,320		0.00	%		1.55	%		13.36	%
Franklin Small-Mid Cap Growth II
Spinnaker & Mainsail
	2009		7.208		612,651		4,416,296		0.00	%		1.40	%		41.58	%
	2008		5.091		619,243		3,152,869		0.00	%		1.40	%		(43.29	%)
	2007		8.978		666,231		5,981,698		0.00	%		1.40	%		9.68	%
	2006		8.185		735,170		6,017,731		0.00	%		1.40	%		7.18	%
	2005		7.637		1,202,220		9,180,922		0.00	%		1.40	%		3.34	%

153

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Franklin Small-Mid Cap Growth II (Continued)
Spinnaker Advisor
	2009	$	6.592		74,671	$	492,239		0.00	%		1.45	%		41.52	%
	2008		4.658		88,484		412,199		0.00	%		1.45	%		(43.33	%)
	2007		8.219		124,839		1,026,098		0.00	%		1.45	%		9.63	%
	2006		7.497		116,867		876,179		0.00	%		1.45	%		7.13	%
	2005		6.998		192,725		1,348,684		0.00	%		1.45	%		3.28	%
Spinnaker Choice
	2009		10.434		1,450		15,123		0.00	%		1.55	%		41.38	%
	2008		7.380		2,081		15,355		0.00	%		1.55	%		(43.38	%)
	2007		13.035		1,943		25,323		0.00	%		1.55	%		9.52	%
	2006		11.902		1,784		21,234		0.00	%		1.55	%		7.02	%
	2005		11.121		1,979		22,008		0.00	%		1.55	%		3.18	%
Franklin U.S. Government II
Spinnaker & Mainsail
	2009		15.058		757,557		11,407,489		3.70	%		1.40	%		1.66	%
	2008		14.812		809,465		11,989,905		4.97	%		1.40	%		6.10	%
	2007		13.961		831,876		11,614,148		4.65	%		1.40	%		5.11	%
	2006		13.282		741,963		9,854,546		4.37	%		1.40	%		2.58	%
	2005		12.948		655,012		8,481,266		4.20	%		1.40	%		0.98	%
Spinnaker Advisor
	2009		14.480		375,668		5,439,571		3.76	%		1.45	%		1.61	%
	2008		14.250		373,639		5,324,424		4.73	%		1.45	%		6.04	%
	2007		13.438		402,186		5,404,757		4.79	%		1.45	%		5.06	%
	2006		12.791		482,575		6,172,446		4.36	%		1.45	%		2.52	%
	2005		12.476		551,197		6,876,576		4.36	%		1.45	%		0.94	%
Spinnaker with EEB
	2009		14.931		622		9,277		3.87	%		1.55	%		1.51	%
	2008		14.709		485		7,136		4.88	%		1.55	%		5.93	%
	2007		13.885		299		4,151		4.67	%		1.55	%		4.96	%
	2006		13.229		103		1,362		0.00	%		1.55	%		32.29	%
Spinnaker Choice
	2009		11.964		48,216		576,834		3.10	%		1.55	%		1.51	%
	2008		11.786		38,533		454,134		4.90	%		1.55	%		5.94	%
	2007		11.125		45,807		509,629		7.02	%		1.55	%		4.96	%
	2006		10.600		36,109		382,752		3.65	%		1.55	%		2.43	%
	2005		10.349		16,479		170,540		1.65	%		1.55	%		0.83	%
Spinnaker Choice with GMDB
	2009		11.829		-		-		0.00	%		1.75	%		1.31	%
	2008		11.676		37		425		5.38	%		1.75	%		5.72	%
	2007		11.044		423		4,678		5.42	%		1.75	%		4.75	%
	2006		10.543		1,445		15,237		4.43	%		1.75	%		2.21	%
	2005		10.315		1,565		16,143		0.00	%		1.75	%		0.63	%
Ibbotson Aggressive Growth Class I
Focus Tier I
	2009		7.631		37,714		287,809		0.63	%		1.35	%		26.07	%
	2008		6.053		14,539		88,006		0.55	%		1.35	%		(37.42	%)
	2007		9.673		6,045		58,472		0.00	%		1.35	%		(3.27	%)
Focus Tier II
	2009		7.641		1,156		8,832		0.08	%		1.30	%		26.13	%
	2008		6.058		11,753		71,199		0.53	%		1.30	%		(37.39	%)
	2007		9.676		-		-		0.00	%		1.30	%		(3.24	%)

154

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Ibbotson Aggressive Growth Class I (Continued)
Focus Tier III
	2009	$	7.661		7,262	$	55,634		0.43	%		1.20	%		26.27	%
	2008		6.067		-		-		0.00	%		1.20	%		(37.34	%)
	2007		9.682		-		-		0.00	%		1.20	%		(3.18	%)
Ibbotson Aggressive Growth Class II
Spinnaker & Mainsail
	2009		8.230		230,416		1,896,121		0.96	%		1.40	%		25.51	%
	2008		6.557		138,585		908,658		0.00	%		1.40	%		(34.43	%)
Spinnaker Advisor
	2009		8.223		2,721		22,374		0.72	%		1.45	%		25.47	%
	2008		6.554		-		-		0.00	%		1.45	%		(34.46	%)
Ibbotson Balanced Class I
Focus Tier I
	2009		8.810		35,160		309,776		0.94	%		1.35	%		18.13	%
	2008		7.458		41,613		310,343		2.39	%		1.35	%		(24.77	%)
	2007		9.913		2,503		24,815		0.00	%		1.35	%		(0.87	%)
Focus Tier II
	2009		8.822		68,011		599,979		1.41	%		1.30	%		18.19	%
	2008		7.464		21,247		158,585		1.48	%		1.30	%		(24.73	%)
	2007		9.916		14,394		142,734		0.00	%		1.30	%		(0.84	%)
Focus Tier III
	2009		8.844		10,038		88,786		0.36	%		1.20	%		18.31	%
	2008		7.475		40,611		303,591		1.65	%		1.20	%		(24.65	%)
	2007		9.921		29,163		289,350		0.00	%		1.20	%		(0.79	%)
Focus Tier II with GMDB
	2009		8.799		22,817		200,776		0.91	%		1.40	%		18.08	%
	2008		7.452		22,817		170,039		1.34	%		1.40	%		(24.80	%)
	2007		9.910		-		-		0.00	%		1.40	%		(0.90	%)
Ibbotson Balanced Class II
Spinnaker & Mainsail
	2009		9.001		352,033		3,168,358		1.22	%		1.40	%		17.86	%
	2008		7.637		34,441		263,016		0.17	%		1.40	%		(23.63	%)
Spinnaker Advisor
	2009		8.993		44,075		396,364		0.97	%		1.40	%		17.80	%
	2008		7.634		-		-		0.00	%		1.40	%		(23.66	%)
Ibbotson Conservative Class I
Focus Tier I
	2009		10.315		4,524		46,672		0.65	%		1.35	%		7.11	%
	2008		9.630		4,152		39,983		2.54	%		1.35	%		(7.12	%)
	2007		10.368		-		-		0.00	%		1.35	%		3.68	%
Focus Tier II
	2009		10.328		6,992		72,233		0.61	%		1.30	%		7.17	%
	2008		9.637		6,964		67,121		0.82	%		1.30	%		(7.08	%)
	2007		10.371		-		-		0.00	%		1.30	%		(0.84	%)
Focus Tier I with GMDB
	2009		10.289		4,275		43,989		0.59	%		1.45	%		7.01	%
	2008		9.615		4,821		46,358		0.98	%		1.45	%		(7.21	%)
	2007		10.362		-		-		0.00	%		1.45	%		3.62	%
Ibbotson Conservative Class II
Spinnaker & Mainsail
	2009		9.873		26,928		265,858		1.08	%		1.40	%		6.77	%
	2008		9.247		1,733		16,024		0.00	%		1.40	%		(7.53	%)

155

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Ibbotson Conservative Class II (Continued)
Spinnaker Advisor
	2009	$	9.865		29,519	$	291,217		0.63	%		1.40	%		6.72	%
	2008		9.244		-		-		0.00	%		1.40	%		(7.56	%)
Ibbotson Growth Class I
Focus Tier I
	2009		8.129		29,723		241,608		0.77	%		1.35	%		23.28	%
	2008		6.594		31,250		206,075		0.13	%		1.35	%		(32.23	%)
	2007		9.730		7,594		73,890		0.00	%		1.35	%		(2.70	%)
Focus Tier II
	2009		8.139		2,140		17,421		0.68	%		1.30	%		23.32	%
	2008		6.600		-		-		0.00	%		1.30	%		(32.19	%)
	2007		9.733		-		-		0.00	%		1.30	%		(2.67	%)
Focus Tier III
	2009		8.160		6,823		55,693		0.66	%		1.20	%		23.45	%
	2008		6.610		48,731		322,122		0.09	%		1.20	%		(32.12	%)
	2007		9.738		-		-		0.00	%		1.20	%		(2.62	%)
Focus Tier I with GMDB
	2009		8.108		-		-		0.00	%		1.45	%		23.15	%
	2008		6.584		17,869		117,654		0.13	%		1.45	%		(32.29	%)
	2007		9.724		-		-		0.00	%		1.45	%		(2.76	%)
Focus Tier II with GMDB
	2009		8.118		22,642		183,824		0.64	%		1.40	%		23.21	%
	2008		6.589		-		-		0.00	%		1.40	%		(32.26	%)
	2007		9.727		-		-		0.00	%		1.40	%		(2.73	%)
Ibbotson Growth Class II
Spinnaker & Mainsail
	2009		8.556		194,864		1,667,251		1.23	%		1.40	%		22.91	%
	2008		6.961		27,677		192,659		0.27	%		1.40	%		(30.39	%)
Spinnaker Advisor
	2009		8.549		13,336		114,008		0.92	%		1.45	%		22.87	%
	2008		6.958		6,499		45,224		0.13	%		1.45	%		(30.42	%)
Ibbotson Income and Growth Class I
Focus Tier I
	2009		9.517		2,671		25,419		1.12	%		1.35	%		12.20	%
	2008		8.482		2,676		22,699		5.29	%		1.35	%		(16.09	%)
	2007		10.109		-		-		0.00	%		1.35	%		1.09	%
Focus Tier II
	2009		9.529		19,709		187,808		1.12	%		1.30	%		12.25	%
	2008		8.489		19,163		162,672		3.41	%		1.30	%		(16.05	%)
	2007		10.112		20,420		206,492		0.00	%		1.30	%		1.12	%
Focus Tier I with GMDB
	2009		9.492		771		7,323		1.16	%		1.45	%		12.08	%
	2008		8.469		782		6,627		3.98	%		1.45	%		(16.17	%)
	2007		10.103		-		-		0.00	%		1.45	%		1.03	%
Ibbotson Income and Growth Class II
Spinnaker & Mainsail
	2009		9.445		80,933		764,349		1.10	%		1.40	%		11.72	%
	2008		8.454		11,770		99,509		0.00	%		1.40	%		(15.46	%)
Spinnaker Advisor
	2009		9.437		20,275		191,347		1.97	%		1.45	%		11.65	%
	2008		8.452		-		-		0.00	%		1.45	%		(15.48	%)

156

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
ING Global Resources
Spinnaker & Mainsail
	2009	$	31.146		53,544	$	1,668,174		0.31	%		1.40	%		35.60	%
	2008		22.969		59,943		1,377,129		1.64	%		1.40	%		(41.82	%)
	2007		39.480		75,621		2,986,040		0.18	%		1.40	%		31.16	%
	2006		30.101		90,613		2,727,542		0.00	%		1.40	%		20.04	%
	2005		25.075		106,767		2,677,217		0.04	%		1.40	%		40.87	%
Spinnaker Advisor
	2009		26.612		2,500		66,564		0.29	%		1.45	%		35.53	%
	2008		19.635		4,622		90,768		1.37	%		1.45	%		(41.85	%)
	2007		33.767		10,620		358,647		0.16	%		1.45	%		31.09	%
	2006		25.758		10,004		257,680		0.00	%		1.45	%		19.98	%
	2005		21.468		27,035		580,395		0.05	%		1.45	%		40.80	%
ING JP Morgan Emerging Markets Equity I
Spinnaker & Mainsail
	2009		22.333		77,533		1,731,630		1.59	%		1.40	%		69.63	%
	2008		13.166		96,211		1,266,779		2.64	%		1.40	%		(51.83	%)
	2007		27.335		112,873		3,085,454		1.17	%		1.40	%		36.87	%
	2006		19.972		131,382		2,623,971		0.64	%		1.40	%		34.29	%
	2005		14.872		163,469		2,431,066		0.71	%		1.40	%		32.99	%
JP Morgan Insurance Trust International Equity I1
Spinnaker & Mainsail
	2009		16.888		392,727		6,633,450		1.55	%		1.40	%		39.32	%
Spinnaker Advisor
	2009		16.832		62,695		1,055,446		1.57	%		1.45	%		39.27	%
Spinnaker with GMDB
	2009		16.698		22		347		1.57	%		1.60	%		39.13	%
Spinnaker Choice
	2009		12.549		3,129		39,281		1.37	%		1.55	%		39.18	%
Spinnaker Choice with GMDB
	2009		12.407		-		-		0.00	%		1.75	%		38.99	%
JP Morgan Insurance Trust Mid Cap Value I1
Spinnaker & Mainsail
	2009		15.143		286,908		4,345,146		0.00	%		1.40	%		28.94	%
Spinnaker Advisor
	2009		15.092		48,086		725,842		0.00	%		1.45	%		28.89	%
Spinnaker with EEB
	2009		15.014		249		3,725		0.00	%		1.55	%		28.80	%
Spinnaker with GMDB
	2009		14.972		122		1,800		0.00	%		1.60	%		28.76	%
Spinnaker Choice
	2009		11.721		3,727		43,695		0.00	%		1.55	%		28.81	%
JP Morgan Insurance Trust U.S. Equity I1
Spinnaker & Mainsail
	2009		7.716		205,475		1,585,710		0.00	%		1.40	%		32.51	%
Spinnaker Advisor
	2009		7.458		226,270		1,687,713		0.00	%		1.45	%		32.48	%
JP Morgan International Equity1
Spinnaker & Mainsail
	2009		12.122		-		-		5.16	%		1.40	%		(4.51	%)
	2008		12.694		431,535		5,478,172		1.78	%		1.40	%		(42.17	%)
	2007		21.951		424,348		9,315,037		1.05	%		1.40	%		7.80	%
	2006		20.362		464,107		9,450,305		1.06	%		1.40	%		20.35	%
	2005		16.919		428,966		7,257,856		0.79	%		1.40	%		9.15	%

157

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
JP Morgan International Equity1 (Continued)
Spinnaker Advisor
	2009	$	12.086		-	$	-		5.07	%		1.45	%		(4.52	%)
	2008		12.658		68,633		868,801		1.79	%		1.45	%		(42.20	%)
	2007		21.900		79,595		1,743,153		1.08	%		1.45	%		7.75	%
	2006		20.325		102,274		2,078,724		1.04	%		1.45	%		20.29	%
	2005		16.897		96,506		1,630,643		0.42	%		1.45	%		9.10	%
Spinnaker with GMDB
	2009		12.002		-		-		5.25	%		1.60	%		(4.56	%)
	2008		12.576		30		367		1.73	%		1.60	%		(42.29	%)
	2007		21.791		30		642		1.10	%		1.60	%		7.59	%
	2006		20.254		30		603		0.59	%		1.60	%		20.11	%
	2005		16.863		8		132		0.00	%		1.60	%		8.94	%
Spinnaker Choice
	2009		9.012		-		-		5.27	%		1.55	%		(4.60	%)
	2008		9.447		4,495		42,461		1.74	%		1.55	%		(42.26	%)
	2007		16.360		4,570		74,773		0.98	%		1.55	%		7.64	%
	2006		15.198		6,274		95,360		1.34	%		1.55	%		20.17	%
	2005		12.647		16,810		212,603		0.03	%		1.55	%		8.99	%
Spinnaker Choice with GMDB
	2009		8.927		-		-		5.19	%		1.75	%		(4.62	%)
	2008		9.359		31		283		2.10	%		1.75	%		(42.37	%)
	2007		16.240		332		5,379		1.19	%		1.75	%		7.43	%
	2006		15.117		1,334		20,161		1.06	%		1.75	%		19.93	%
	2005		12.605		1,444		18,206		0.00	%		1.75	%		8.78	%
JP Morgan Mid-Cap Value1
Spinnaker & Mainsail
	2009		11.744		-		-		2.60	%		1.40	%		(3.12	%)
	2008		12.122		315,960		3,830,174		1.10	%		1.40	%		(34.14	%)
	2007		18.405		355,902		6,550,540		0.86	%		1.40	%		1.02	%
	2006		18.219		357,762		6,518,179		0.59	%		1.40	%		15.22	%
	2005		15.812		307,615		4,864,142		0.17	%		1.40	%		7.70	%
Spinnaker Advisor
	2009		11.709		-		-		2.43	%		1.45	%		(3.14	%)
	2008		12.088		66,039		798,286		1.14	%		1.45	%		(34.17	%)
	2007		18.362		100,305		1,841,860		0.89	%		1.45	%		0.97	%
	2006		18.186		97,696		1,776,693		0.53	%		1.45	%		15.17	%
	2005		15.791		109,221		1,724,751		0.13	%		1.45	%		7.64	%
Spinnaker with EEB
	2009		11.656		-		-		2.92	%		1.55	%		(3.16	%)
	2008		12.037		174		2,087		0.99	%		1.55	%		(34.24	%)
	2007		18.304		96		1,757		0.73	%		1.55	%		0.87	%
	2006		18.146		34		618		0.00	%		1.55	%		81.46	%
Spinnaker with GMDB
	2009		11.627		-		-		2.68	%		1.60	%		(3.18	%)
	2008		12.009		116		1,376		1.09	%		1.60	%		(34.27	%)
	2007		18.271		111		2,021		0.91	%		1.60	%		0.82	%
	2006		18.122		19		352		0.00	%		1.60	%		81.22	%
Spinnaker Choice
	2009		9.100		-		-		2.66	%		1.55	%		(3.17	%)
	2008		9.397		3,800		35,709		1.01	%		1.55	%		(34.24	%)
	2007		14.289		3,010		43,017		1.15	%		1.55	%		0.87	%
	2006		14.166		13,230		187,424		0.39	%		1.55	%		15.05	%
	2005		12.313		4,004		49,299		0.00	%		1.55	%		7.54	%

158

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
JP Morgan US Large Cap Core Equity1
Spinnaker & Mainsail
	2009	$	5.823		-	$	-		2.61	%		1.40	%		(1.49	%)
	2008		5.911		232,537		1,374,647		1.38	%		1.40	%		(34.90	%)
	2007		9.080		281,098		2,552,470		1.12	%		1.40	%		0.24	%
	2006		9.058		337,181		3,054,407		1.02	%		1.40	%		14.95	%
	2005		7.880		417,620		3,290,769		1.26	%		1.40	%		(0.05	%)
Spinnaker Advisor
	2009		5.630		-		-		2.61	%		1.45	%		(1.51	%)
	2008		5.716		244,263		1,396,309		1.40	%		1.45	%		(34.93	%)
	2007		8.785		285,380		2,507,096		1.16	%		1.45	%		0.19	%
	2006		8.768		393,426		3,449,744		0.99	%		1.45	%		14.90	%
	2005		7.631		467,924		3,570,828		1.31	%		1.45	%		(0.10	%)
Mutual Shares Securities
Spinnaker & Mainsail
	2009		11.630		614,281		7,144,093		1.95	%		1.40	%		24.29	%
	2008		9.357		607,390		5,683,171		3.05	%		1.40	%		(37.98	%)
	2007		15.087		593,186		8,949,714		1.40	%		1.40	%		2.03	%
	2006		14.787		512,957		7,585,022		1.34	%		1.40	%		16.75	%
	2005		12.666		425,366		5,387,871		0.90	%		1.40	%		9.02	%
Spinnaker Advisor
	2009		11.585		57,337		664,268		1.93	%		1.45	%		24.24	%
	2008		9.325		47,652		444,374		3.09	%		1.45	%		(38.02	%)
	2007		15.045		49,897		750,681		1.52	%		1.45	%		1.98	%
	2006		14.752		34,647		511,123		1.44	%		1.45	%		16.68	%
	2005		12.643		51,258		648,060		0.81	%		1.45	%		8.96	%
Spinnaker with GMDB
	2009		11.499		802		9,190		1.95	%		1.60	%		24.06	%
	2008		9.269		802		7,414		3.03	%		1.60	%		(38.11	%)
	2007		14.977		802		11,995		1.43	%		1.60	%		1.83	%
	2006		14.708		802		11,792		1.31	%		1.60	%		16.51	%
	2005		12.624		802		10,125		1.26	%		1.60	%		8.80	%
Spinnaker Choice
	2009		10.848		5,235		56,786		2.01	%		1.55	%		24.10	%
	2008		8.741		5,071		44,330		3.00	%		1.55	%		(38.08	%)
	2007		14.116		5,781		81,598		1.42	%		1.55	%		1.88	%
	2006		13.855		7,498		103,880		0.63	%		1.55	%		16.57	%
	2005		11.886		1,661		19,744		1.11	%		1.55	%		8.86	%
Spinnaker Choice with GMDB
	2009		10.726		564		6,032		1.94	%		1.75	%		23.87	%
	2008		8.659		564		4,873		3.03	%		1.75	%		(38.20	%)
	2007		14.012		564		7,889		1.42	%		1.75	%		1.67	%
	2006		13.782		564		7,768		1.31	%		1.75	%		16.33	%
	2005		11.847		564		6,676		0.00	%		1.75	%		8.65	%
Neuberger Berman AMT Guardian Class S
Spinnaker & Mainsail
	2009		8.324		5,719		47,606		1.05	%		1.40	%		27.71	%
	2008		6.518		5,076		33,086		1.06	%		1.40	%		(34.82	%)
Spinnaker Advisor
	2009		8.317		28		214		1.22	%		1.45	%		27.64	%
	2008		6.516		9		61		0.00	%		1.45	%		(34.84	%)
Neuberger Berman AMT Mid Cap Growth Class S
Spinnaker & Mainsail
	2009		8.033		43,714		351,142		0.00	%		1.40	%		29.52	%
	2008		6.202		23,828		147,785		0.00	%		1.40	%		(37.98	%)

159

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Neuberger Berman AMT Mid Cap Growth Class S (Continued)
Spinnaker Advisor
	2009	$	8.026		4,353	$	34,931		0.00	%		1.45	%		29.45	%
	2008		6.200		31		193		0.00	%		1.45	%		(38.00	%)
Neuberger Berman AMT Regency Class S
Spinnaker & Mainsail
	2009		8.013		2,069		16,575		1.11	%		1.40	%		44.12	%
	2008		5.560		-		-		0.00	%		1.40	%		(44.40	%)
PIMCO All Asset Portfolio Advisor
Spinnaker & Mainsail
	2009		11.387		36,300		413,365		6.96	%		1.40	%		19.74	%
	2008		9.510		22,161		210,752		6.18	%		1.40	%		(17.08	%)
	2007		11.469		14,588		167,306		7.13	%		1.40	%		6.68	%
	2006		10.751		17,780		191,160		5.90	%		1.40	%		3.11	%
	2005		10.427		11,226		117,045		5.73	%		1.40	%		4.19	%
Spinnaker Advisor
	2009		11.361		3,128		35,535		7.08	%		1.45	%		19.68	%
	2008		9.493		2,876		27,295		6.15	%		1.45	%		(17.12	%)
	2007		11.454		2,459		28,162		7.26	%		1.45	%		6.63	%
	2006		10.742		5,239		56,279		5.29	%		1.45	%		3.06	%
	2005		10.423		5,200		54,204		4.27	%		1.45	%		4.15	%
Spinnaker Choice
	2009		11.308		11		116		6.64	%		1.55	%		19.56	%
	2008		9.458		11		103		5.70	%		1.55	%		(17.20	%)
	2007		11.423		12		132		1.56	%		1.55	%		6.51	%
	2006		10.724		1,451		15,555		6.95	%		1.55	%		7.24	%
PIMCO Commodity Fund Admin
Spinnaker & Mainsail
	2009		9.833		298,984		2,939,992		6.14	%		1.40	%		39.55	%
	2008		7.046		239,853		1,689,955		4.66	%		1.40	%		(44.57	%)
	2007		12.712		192,212		2,443,409		4.80	%		1.40	%		21.52	%
	2006		10.461		145,969		1,526,963		5.22	%		1.40	%		(4.44	%)
	2005		10.947		86,327		945,040		2.27	%		1.40	%		10.35	%
Spinnaker Advisor
	2009		9.810		57,481		563,905		6.40	%		1.45	%		39.49	%
	2008		7.033		42,197		296,764		4.27	%		1.45	%		(44.60	%)
	2007		12.695		51,262		650,775		4.52	%		1.45	%		21.46	%
	2006		10.452		59,485		621,744		5.16	%		1.45	%		(4.50	%)
	2005		10.944		41,710		456,452		1.94	%		1.45	%		10.32	%
Spinnaker with EEB
	2009		9.764		217		2,103		6.41	%		1.55	%		39.35	%
	2008		7.007		150		1,044		4.90	%		1.55	%		(44.66	%)
	2007		12.661		93		1,169		5.33	%		1.55	%		21.33	%
	2006		10.435		32		329		14.46	%		1.55	%		4.35	%
Spinnaker with GMDB
	2009		9.742		-		-		1.85	%		1.60	%		39.29	%
	2008		6.994		3		23		4.80	%		1.60	%		(44.69	%)
	2007		12.644		3		42		5.56	%		1.60	%		21.27	%
	2006		10.426		3		35		5.68	%		1.60	%		(4.64	%)
	2005		10.933		3		36		2.83	%		1.60	%		10.21	%
Spinnaker Choice
	2009		9.764		8,781		85,709		5.55	%		1.55	%		39.35	%
	2008		7.007		14,916		104,492		6.22	%		1.55	%		(44.66	%)
	2007		12.661		3,202		40,543		4.63	%		1.55	%		21.33	%
	2006		10.435		2,441		25,473		4.03	%		1.55	%		4.58	%
	2005		10.936		3,744		40,942		2.59	%		1.55	%		10.24	%

160

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
PIMCO Commodity Fund Admin (Continued)
Spinnaker Choice with GMDB
	2009	$	9.673		245	$	2,380		5.84	%		1.75	%		39.06	%
	2008		6.956		257		1,791		4.26	%		1.75	%		(44.76	%)
	2007		12.593		360		4,541		5.15	%		1.75	%		21.09	%
	2006		10.400		346		3,598		4.51	%		1.75	%		4.77	%
	2005		10.921		375		4,091		46.96	%		1.75	%		10.09	%
Pioneer Bond VCT Class I
Spinnaker & Mainsail
	2009		31.294		132,369		4,139,523		5.58	%		1.40	%		15.99	%
	2008		26.980		153,308		4,135,066		5.29	%		1.40	%		(2.02	%)
	2007		27.535		187,451		5,160,148		4.97	%		1.40	%		5.08	%
	2006		26.205		217,260		5,692,739		5.21	%		1.40	%		3.25	%
	2005		25.381		250,370		6,354,708		9.87	%		1.40	%		1.20	%
Spinnaker Advisor
	2009		15.314		70,178		1,073,878		5.57	%		1.45	%		15.94	%
	2008		13.209		81,374		1,074,537		5.29	%		1.45	%		(2.07	%)
	2007		13.488		97,167		1,310,213		4.97	%		1.45	%		5.02	%
	2006		12.843		118,254		1,518,553		5.19	%		1.45	%		3.20	%
	2005		12.445		141,769		1,764,370		9.64	%		1.45	%		1.15	%
Pioneer Emerging Markets VCT Class II
Spinnaker & Mainsail
	2009		18.734		159,022		2,979,178		0.89	%		1.40	%		71.60	%
	2008		10.917		140,560		1,534,542		0.09	%		1.40	%		(58.89	%)
	2007		26.553		129,290		3,433,027		0.32	%		1.40	%		40.46	%
	2006		18.904		96,275		1,819,963		0.35	%		1.40	%		33.63	%
	2005		14.147		21,555		304,935		0.19	%		1.40	%		35.70	%
Spinnaker Advisor
	2009		18.687		38,750		724,121		0.86	%		1.45	%		71.52	%
	2008		10.895		29,956		326,374		0.08	%		1.45	%		(58.91	%)
	2007		26.512		27,484		728,642		0.34	%		1.45	%		40.39	%
	2006		18.884		16,505		311,684		0.27	%		1.45	%		33.56	%
	2005		14.139		3,228		45,636		0.14	%		1.45	%		35.64	%
Spinnaker with GMDB
	2009		18.545		682		12,626		0.88	%		1.60	%		71.27	%
	2008		10.828		682		7,370		0.09	%		1.60	%		(58.97	%)
	2007		26.390		682		17,944		0.34	%		1.60	%		40.18	%
	2006		18.826		661		12,438		0.40	%		1.60	%		88.26	%
Spinnaker Choice
	2009		18.592		2,510		46,668		0.88	%		1.55	%		71.34	%
	2008		10.851		3,406		36,963		0.09	%		1.55	%		(58.94	%)
	2007		26.430		15,356		405,879		0.61	%		1.55	%		40.25	%
	2006		18.845		22,694		427,676		0.05	%		1.55	%		88.45	%
Pioneer Equity Income VCT Class II
Spinnaker & Mainsail
	2009		9.778		344,220		3,365,682		3.12	%		1.40	%		12.31	%
	2008		8.706		271,283		2,361,796		2.62	%		1.40	%		(31.45	%)
	2007		12.700		242,577		3,080,684		2.41	%		1.40	%		(0.86	%)
	2006		12.810		147,363		1,887,770		1.64	%		1.40	%		20.43	%
	2005		10.637		480,888		5,115,226		2.48	%		1.40	%		4.06	%
Spinnaker Advisor
	2009		9.753		30,789		300,278		3.16	%		1.45	%		12.26	%
	2008		8.688		24,587		213,620		2.49	%		1.45	%		(31.48	%)
	2007		12.680		29,081		368,751		2.22	%		1.45	%		(0.91	%)
	2006		12.797		30,516		390,508		3.42	%		1.45	%		20.37	%
	2005		10.631		11,713		124,524		2.79	%		1.45	%		4.00	%

161

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Pioneer Equity Income VCT Class II (Continued)
Spinnaker with GMDB
	2009	$	9.679		65	$	592		3.11	%		1.60	%		12.09	%
	2008		8.635		61		515		2.65	%		1.60	%		(31.59	%)
	2007		12.622		57		717		2.54	%		1.60	%		(1.06	%)
	2006		12.757		26		337		3.50	%		1.60	%		27.57	%
Spinnaker Choice
	2009		9.703		4,676		45,366		3.10	%		1.55	%		12.13	%
	2008		8.653		5,335		46,157		2.49	%		1.55	%		(31.55	%)
	2007		12.641		3,009		38,021		2.68	%		1.55	%		(1.01	%)
Pioneer Fund VCT Class I
Spinnaker & Mainsail
	2009		48.511		845,050		40,995,646		1.81	%		1.40	%		23.46	%
	2008		39.293		963,940		37,877,452		1.82	%		1.40	%		(35.18	%)
	2007		60.622		1,130,394		68,527,840		1.20	%		1.40	%		3.52	%
	2006		58.560		1,341,636		78,567,204		1.33	%		1.40	%		15.02	%
	2005		50.915		1,564,272		79,644,315		1.31	%		1.40	%		4.70	%
Spinnaker Advisor
	2009		7.614		47,186		359,294		1.83	%		1.45	%		23.40	%
	2008		6.170		57,815		356,755		1.83	%		1.45	%		(35.22	%)
	2007		9.524		66,706		635,356		1.16	%		1.45	%		3.47	%
	2006		9.205		100,061		921,084		1.34	%		1.45	%		14.96	%
	2005		8.007		110,226		882,608		1.28	%		1.45	%		4.65	%
Pioneer Growth Opportunities VCT Class I
Spinnaker & Mainsail
	2009		42.971		921,763		39,610,528		0.00	%		1.40	%		42.55	%
	2008		30.144		1,023,845		30,863,857		0.00	%		1.40	%		(36.39	%)
	2007		47.389		1,210,224		57,351,857		0.00	%		1.40	%		(5.20	%)
	2006		49.990		1,473,487		73,660,152		0.00	%		1.40	%		4.13	%
	2005		48.006		1,788,116		85,840,023		0.00	%		1.40	%		5.21	%
Spinnaker Advisor
	2009		10.086		109,326		1,102,721		0.00	%		1.45	%		42.48	%
	2008		7.079		135,150		956,754		0.00	%		1.45	%		(36.42	%)
	2007		11.134		172,763		1,923,600		0.00	%		1.45	%		(5.25	%)
	2006		11.751		221,561		2,603,634		0.00	%		1.45	%		4.08	%
	2005		11.290		325,607		3,676,253		0.00	%		1.45	%		5.15	%
Pioneer High Yield VCT Class II
Spinnaker & Mainsail
	2009		11.292		104,662		1,180,820		7.70	%		1.40	%		58.04	%
	2008		7.145		93,574		669,051		8.30	%		1.40	%		(36.61	%)
	2007		11.272		71,285		803,380		5.10	%		1.40	%		4.13	%
	2006		10.825		19,265		208,522		5.39	%		1.40	%		6.74	%
	2005		10.141		8,138		82,522		5.20	%		1.40	%		0.28	%
Spinnaker Advisor
	2009		11.264		18,223		205,140		6.81	%		1.45	%		57.98	%
	2008		7.130		7,559		53,970		8.06	%		1.45	%		(36.65	%)
	2007		11.255		9,127		102,719		5.15	%		1.45	%		4.08	%
	2006		10.814		5,171		55,918		5.40	%		1.45	%		6.70	%
	2005		10.135		1,784		18,082		5.15	%		1.45	%		0.23	%
Spinnaker with GMDB
	2009		11.178		-		-		11.32	%		1.60	%		57.73	%
	2008		7.087		19		137		8.22	%		1.60	%		(36.74	%)
	2007		11.203		20		220		0.46	%		1.60	%		3.92	%

162

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Pioneer High Yield VCT Class II (Continued)
Spinnaker Choice
	2009	$	11.207		10,755	$	120,307		8.13	%		1.55	%		57.82	%
	2008		7.101		144,013		1,022,461		7.79	%		1.55	%		(36.71	%)
	2007		11.220		3,758		42,149		5.16	%		1.55	%		3.97	%
	2006		10.791		1,353		14,592		5.56	%		1.55	%		7.91	%
Pioneer Mid-Cap Value VCT Class I
Spinnaker & Mainsail
	2009		21.431		399,310		8,557,915		1.55	%		1.40	%		23.84	%
	2008		17.306		454,540		7,866,348		1.14	%		1.40	%		(34.50	%)
	2007		26.423		538,761		14,236,103		0.77	%		1.40	%		4.11	%
	2006		25.381		633,805		16,086,897		1.02	%		1.40	%		11.03	%
	2005		22.859		741,101		16,941,202		0.30	%		1.40	%		6.39	%
Spinnaker Advisor
	2009		8.493		32,975		280,079		1.63	%		1.45	%		23.77	%
	2008		6.862		37,307		256,013		1.11	%		1.45	%		(34.54	%)
	2007		10.483		46,660		489,130		0.76	%		1.45	%		4.06	%
	2006		10.074		50,785		511,625		1.02	%		1.45	%		10.97	%
	2005		9.078		64,279		583,512		0.31	%		1.45	%		6.34	%
Pioneer Money Market VCT Class I
Spinnaker & Mainsail
	2009		18.581		156,354		2,904,163		0.18	%		1.40	%		(1.22	%)
	2008		18.811		175,076		3,292,332		2.38	%		1.40	%		0.96	%
	2007		18.633		207,966		3,873,948		4.71	%		1.40	%		3.38	%
	2006		18.025		249,012		4,488,253		4.37	%		1.40	%		3.05	%
	2005		17.491		286,711		5,014,832		2.41	%		1.40	%		1.05	%
Spinnaker Advisor
	2009		10.980		60,188		660,549		0.17	%		1.45	%		(1.28	%)
	2008		11.122		62,162		691,032		2.37	%		1.45	%		0.91	%
	2007		11.022		67,370		742,230		4.73	%		1.45	%		3.32	%
	2006		10.667		137,671		1,468,556		4.47	%		1.45	%		2.99	%
	2005		10.357		98,224		1,017,284		2.34	%		1.45	%		1.00	%
Pioneer Real Estate VCT Class II
Spinnaker & Mainsail
	2009		7.638		282,324		2,156,337		4.54	%		1.40	%		29.72	%
	2008		5.888		213,271		1,255,660		4.18	%		1.40	%		(39.20	%)
	2007		9.685		158,789		1,537,852		2.90	%		1.40	%		(20.23	%)
	2006		12.141		61,478		746,397		2.45	%		1.40	%		21.41	%
Spinnaker Advisor
	2009		7.624		70,934		540,781		4.51	%		1.45	%		29.66	%
	2008		5.880		62,604		368,094		4.10	%		1.45	%		(39.24	%)
	2007		9.677		47,621		460,824		2.66	%		1.45	%		(20.27	%)
	2006		12.137		21,226		257,617		2.20	%		1.45	%		21.37	%
Spinnaker with EEB
	2009		7.596		267		2,007		4.56	%		1.55	%		29.54	%
	2008		5.864		170		988		4.42	%		1.55	%		(39.30	%)
	2007		9.661		88		847		3.04	%		1.55	%		(20.35	%)
	2006		12.129		30		363		2.65	%		1.55	%		21.29	%
Spinnaker with GMDB
	2009		7.582		77		555		4.51	%		1.60	%		29.47	%
	2008		5.856		77		446		4.03	%		1.60	%		(39.33	%)
	2007		9.652		77		738		2.58	%		1.60	%		(20.40	%)

163

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Pioneer Real Estate VCT Class II (Continued)
Spinnaker Choice
	2009	$	7.596		5,322	$	40,419		4.52	%		1.55	%		29.54	%
	2008		5.864		5,516		32,344		4.55	%		1.55	%		(39.30	%)
	2007		9.661		3,698		35,718		2.29	%		1.55	%		(20.35	%)
	2006		12.129		8,742		106,025		2.57	%		1.55	%		21.29	%
Pioneer Small-Cap Value VCT Class I1
Spinnaker & Mainsail
	2009		13.606		-		-		1.09	%		1.40	%		(4.38	%)
	2008		14.229		390,883		5,562,029		0.59	%		1.40	%		(38.87	%)
	2007		23.276		505,500		11,765,839		0.70	%		1.40	%		(8.26	%)
	2006		25.372		600,759		15,242,261		0.82	%		1.40	%		10.71	%
	2005		22.917		675,901		15,489,898		0.61	%		1.40	%		13.35	%
Spinnaker Advisor
	2009		11.757		-		-		0.95	%		1.45	%		(4.40	%)
	2008		12.298		86,119		1,059,122		0.62	%		1.45	%		(38.90	%)
	2007		20.127		119,200		2,399,149		0.71	%		1.45	%		(8.31	%)
	2006		21.951		172,660		3,789,995		0.81	%		1.45	%		10.66	%
	2005		19.837		251,176		4,982,639		0.58	%		1.45	%		13.30	%
Spinnaker with GMDB
	2009		13.471		-		-		1.60	%		1.60	%		(4.44	%)
	2008		14.097		87		1,219		0.60	%		1.60	%		(38.99	%)
	2007		23.105		87		2,004		0.69	%		1.60	%		(8.45	%)
	2006		25.237		87		2,204		0.81	%		1.60	%		10.49	%
	2005		22.841		87		1,998		0.61	%		1.60	%		13.12	%
Pioneer Small-Cap Value VCT Class II1
Spinnaker & Mainsail
	2009		6.688		-		-		0.65	%		1.40	%		(4.62	%)
	2008		7.012		230,887		1,618,999		0.24	%		1.40	%		(38.97	%)
	2007		11.489		237,023		2,723,252		0.52	%		1.40	%		(8.48	%)
	2006		12.554		231,065		2,900,693		0.00	%		1.40	%		12.56	%
	2005		11.153		229,855		2,563,540		0.00	%		1.40	%		9.56	%
Spinnaker Advisor
	2009		6.674		-		-		0.67	%		1.45	%		(4.63	%)
	2008		6.998		39,270		274,802		0.24	%		1.45	%		(39.00	%)
	2007		11.472		65,847		755,382		0.50	%		1.45	%		(8.52	%)
	2006		12.541		73,594		922,912		0.00	%		1.45	%		12.51	%
	2005		11.147		54,401		606,401		0.00	%		1.45	%		9.51	%
Spinnaker with EEB
	2009		6.644		-		-		3.36	%		1.55	%		(4.66	%)
	2008		6.969		194		1,347		0.22	%		1.55	%		(39.06	%)
	2007		11.436		103		1,172		0.47	%		1.55	%		(8.62	%)
	2006		12.515		36		444		0.00	%		1.55	%		25.15	%
Spinnaker with GMDB
	2009		6.630		-		-		0.88	%		1.60	%		(4.67	%)
	2008		6.955		55		373		0.19	%		1.60	%		(39.09	%)
	2007		11.419		55		617		0.44	%		1.60	%		(8.66	%)
	2006		12.502		55		680		0.00	%		1.60	%		12.34	%
	2005		11.129		3		29		0.00	%		1.60	%		9.33	%
Spinnaker Choice
	2009		6.644		-		-		0.40	%		1.55	%		(4.66	%)
	2008		6.969		3,062		21,337		0.24	%		1.55	%		(39.06	%)
	2007		11.436		3,534		40,407		0.46	%		1.55	%		(8.62	%)
	2006		12.515		4,914		61,495		0.00	%		1.55	%		12.39	%
	2005		11.135		3,803		42,343		0.00	%		1.55	%		9.40	%

164

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Pioneer Small-Cap Value VCT Class II1 (Continued)
Spinnaker Choice with GMDB
	2009	$	6.586		-	$	-		0.92	%		1.75	%		(4.71	%)
	2008		6.912		7		43		0.25	%		1.75	%		(39.19	%)
	2007		11.366		67		757		0.54	%		1.75	%		(8.80	%)
	2006		12.463		252		3,142		0.00	%		1.75	%		12.17	%
	2005		11.111		273		3,035		0.00	%		1.75	%		9.17	%
Pioneer Strategic Income VCT Class II
Spinnaker & Mainsail
	2009		12.460		276,227		3,441,768		7.88	%		1.40	%		27.48	%
	2008		9.774		198,836		1,944,023		6.80	%		1.40	%		(12.95	%)
	2007		11.228		130,537		1,465,496		5.19	%		1.40	%		4.69	%
	2006		10.725		38,174		409,361		5.24	%		1.40	%		4.77	%
	2005		10.237		25,365		259,657		5.62	%		1.40	%		1.07	%
Spinnaker Advisor
	2009		12.428		58,058		721,522		7.98	%		1.45	%		27.41	%
	2008		9.754		48,933		477,426		6.91	%		1.45	%		(13.00	%)
	2007		11.211		31,512		353,217		5.15	%		1.45	%		4.64	%
	2006		10.713		13,211		141,523		5.16	%		1.45	%		4.71	%
	2005		10.231		31,103		318,214		5.63	%		1.45	%		1.01	%
Spinnaker Choice
	2009		12.365		3,633		44,843		7.85	%		1.55	%		27.28	%
	2008		9.715		2,499		24,246		6.80	%		1.55	%		(13.08	%)
	2007		11.177		3,723		41,594		5.24	%		1.55	%		4.54	%
	2006		10.691		627		6,705		5.24	%		1.55	%		4.61	%
	2005		10.220		435		4,443		5.69	%		1.55	%		0.91	%
Summit Balance Index
Spinnaker & Mainsail
	2009		9.255		6,943		64,254		2.95	%		1.40	%		16.77	%
	2008		7.926		305		2,411		1.25	%		1.40	%		(20.74	%)
Summit Barclays Aggregate Bond Index
Spinnaker & Mainsail
	2009		10.667		90,933		970,011		7.91	%		1.40	%		3.13	%
	2008		10.343		26,513		274,227		3.11	%		1.40	%		3.43	%
Spinnaker Advisor
	2009		10.658		14,176		151,118		9.24	%		1.45	%		3.08	%
	2008		10.340		1,457		15,072		2.52	%		1.45	%		3.40	%
Summit EAFE International Index F Class
Spinnaker & Mainsail
	2009		7.419		3,160		23,478		1.42	%		1.40	%		25.72	%
	2008		5.901		23		137		0.00	%		1.40	%		(40.99	%)
Spinnaker Advisor
	2009		7.413		8,361		61,893		3.75	%		1.45	%		25.67	%
	2008		5.899		-		-		0.00	%		1.45	%		(41.01	%)
Summit NASDAQ 100 Index
Spinnaker & Mainsail
	2009		9.474		8,298		78,617		0.12	%		1.40	%		51.37	%
	2008		6.259		1,345		8,416		0.14	%		1.40	%		(37.41	%)
Spinnaker Advisor
	2009		9.466		802		7,603		0.10	%		1.45	%		51.29	%
	2008		6.257		-		-		0.00	%		1.45	%		(37.43	%)
Summit Russell 2000 Small Cap Index F Class
Spinnaker & Mainsail
	2009		8.656		74,597		645,726		0.39	%		1.40	%		24.23	%
	2008		6.968		21,303		148,448		0.64	%		1.40	%		(30.32	%)

165

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Summit Russell 2000 Small Cap Index F Class (Continued)
Spinnaker Advisor
	2009	$	8.649		16,421	$	142,036		0.41	%		1.45	%		24.16	%
	2008		6.966		3,327		23,183		0.36	%		1.45	%		(30.34	%)
Summit S&P Mid Cap 400 Index F Class
Spinnaker & Mainsail
	2009		8.582		8,833		75,818		0.29	%		1.40	%		34.20	%
	2008		6.395		1,965		12,566		0.70	%		1.40	%		(36.05	%)
Templeton Developing Markets II
Spinnaker & Mainsail
	2009		21.274		223,664		4,758,030		3.97	%		1.40	%		70.19	%
	2008		12.500		219,489		2,743,459		2.74	%		1.40	%		(53.36	%)
	2007		26.803		222,156		5,954,562		2.23	%		1.40	%		26.98	%
	2006		21.107		206,618		4,361,163		1.11	%		1.40	%		26.31	%
	2005		16.710		169,302		2,829,088		1.26	%		1.40	%		25.66	%
Spinnaker Advisor
	2009		22.003		32,728		720,107		4.31	%		1.45	%		70.12	%
	2008		12.934		33,949		439,116		2.35	%		1.45	%		(53.39	%)
	2007		27.749		59,929		1,662,974		2.24	%		1.45	%		26.92	%
	2006		21.863		69,301		1,515,144		1.11	%		1.45	%		26.25	%
	2005		17.317		67,312		1,165,654		1.09	%		1.45	%		25.59	%
Spinnaker Choice
	2009		19.297		1,229		23,712		6.40	%		1.55	%		69.94	%
	2008		11.355		2,271		25,794		2.50	%		1.55	%		(53.44	%)
	2007		24.386		11,472		279,748		1.51	%		1.55	%		26.79	%
	2006		19.233		17,149		329,815		0.91	%		1.55	%		26.13	%
	2005		15.249		4,004		61,063		0.34	%		1.55	%		25.48	%
Spinnaker Choice with GMDB
	2009		19.080		128		2,448		4.81	%		1.75	%		69.60	%
	2008		11.250		161		1,811		2.63	%		1.75	%		(53.53	%)
	2007		24.208		124		3,014		0.00	%		1.75	%		26.54	%
Templeton Global Bond Securities II1
Spinnaker & Mainsail
	2009		14.633		356,507		5,216,618		13.77	%		1.40	%		17.04	%
	2008		12.503		280,417		3,506,054		3.43	%		1.40	%		4.73	%
	2007		11.938		132,745		1,584,750		2.13	%		1.40	%		9.45	%
	2006		10.907		45,542		496,738		3.00	%		1.40	%		11.21	%
	2005		9.808		27,212		266,901		6.15	%		1.40	%		2.05	%
Spinnaker Advisor
	2009		14.598		57,500		839,397		13.57	%		1.45	%		16.97	%
	2008		12.480		36,287		452,866		3.80	%		1.45	%		4.68	%
	2007		11.922		53,948		643,175		2.52	%		1.45	%		9.39	%
	2006		10.898		23,753		258,863		1.82	%		1.45	%		11.15	%
	2005		9.805		8,039		78,817		5.23	%		1.45	%		2.08	%
Spinnaker with GMDB
	2009		14.496		-		-		26.73	%		1.60	%		16.80	%
	2008		12.411		109		1,343		3.62	%		1.60	%		4.51	%
	2007		11.875		110		1,301		0.00	%		1.60	%		9.24	%
Spinnaker Choice
	2009		14.530		5,756		83,609		14.56	%		1.55	%		16.86	%
	2008		12.434		6,173		76,734		3.96	%		1.55	%		4.58	%
	2007		11.890		5,105		60,706		2.61	%		1.55	%		9.28	%
	2006		10.880		2,145		23,339		0.00	%		1.55	%		8.80	%

166

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Templeton Global Bond Securities II1 (Continued)
Spinnaker Choice with GMDB
	2009	$	14.395		285	$	4,095		14.37	%		1.75	%		16.62	%
	2008		12.343		286		3,520		3.63	%		1.75	%		4.36	%
	2007		11.827		284		3,361		2.79	%		1.75	%		9.07	%
	2006		10.844		286		3,096		4.66	%		1.75	%		8.44	%
Templeton Growth Securities II
Spinnaker & Mainsail
	2009		11.333		491,961		5,574,153		3.17	%		1.40	%		29.28	%
	2008		8.766		467,717		4,099,122		1.77	%		1.40	%		(43.13	%)
	2007		15.413		449,320		6,925,660		1.32	%		1.40	%		0.91	%
	2006		15.273		408,888		6,245,212		1.32	%		1.40	%		20.12	%
	2005		12.715		348,066		4,425,710		1.13	%		1.40	%		7.35	%
Spinnaker Advisor
	2009		11.290		31,517		355,816		3.20	%		1.45	%		29.22	%
	2008		8.737		34,135		298,231		1.80	%		1.45	%		(43.16	%)
	2007		15.370		35,308		542,691		1.51	%		1.45	%		0.87	%
	2006		15.238		28,349		431,989		1.28	%		1.45	%		20.06	%
	2005		12.692		33,757		428,440		1.07	%		1.45	%		7.30	%
Spinnaker with GMDB
	2009		11.205		659		7,384		3.14	%		1.60	%		29.02	%
	2008		8.685		659		5,721		1.78	%		1.60	%		(43.24	%)
	2007		15.301		659		10,081		1.31	%		1.60	%		0.72	%
	2006		15.192		659		10,019		1.34	%		1.60	%		19.88	%
	2005		12.673		659		8,357		1.74	%		1.60	%		7.14	%
Spinnaker Choice
	2009		10.657		2,882		30,704		2.92	%		1.55	%		29.08	%
	2008		8.256		4,176		34,470		1.78	%		1.55	%		(43.21	%)
	2007		14.538		4,415		64,185		1.13	%		1.55	%		0.77	%
	2006		14.427		5,869		84,673		1.36	%		1.55	%		19.94	%
	2005		12.029		3,641		43,793		1.51	%		1.55	%		7.20	%
Spinnaker Choice with GMDB
	2009		10.537		558		5,877		3.15	%		1.75	%		28.83	%
	2008		8.179		558		4,566		1.78	%		1.75	%		(43.32	%)
	2007		14.431		558		8,058		1.32	%		1.75	%		0.56	%
	2006		14.351		558		8,012		1.34	%		1.75	%		19.70	%
	2005		11.989		558		6,690		0.00	%		1.75	%		6.99	%
Vanguard Balanced
Focus Tier I
	2009		9.276		26,972		250,185		3.91	%		1.35	%		21.25	%
	2008		7.650		23,163		177,188		3.10	%		1.35	%		(23.61	%)
	2007		10.014		16,968		169,919		0.00	%		1.35	%		0.14	%
Focus Tier II
	2009		9.288		3,006		27,917		1.59	%		1.30	%		21.32	%
	2008		7.656		774		5,924		0.00	%		1.30	%		(23.57	%)
	2007		10.017		-		-		0.00	%		1.30	%		0.17	%
Focus Tier III
	2009		9.312		8,215		76,492		4.42	%		1.20	%		21.44	%
	2008		7.668		8,215		62,991		3.42	%		1.20	%		(23.50	%)
	2007		10.023		8,215		82,337		0.00	%		1.20	%		0.23	%
Focus Tier I with GMDB
	2009		9.252		327		3,009		4.42	%		1.45	%		21.13	%
	2008		7.638		332		2,532		0.00	%		1.45	%		(23.69	%)
	2007		10.009		-		-		0.00	%		1.45	%		0.09	%

167

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Vanguard Balanced (Continued)
Focus Tier II with GMDB
	2009	$	9.264		38,110	$	353,038		4.53	%		1.40	%		21.19	%
	2008		7.644		39,579		302,530		0.00	%		1.40	%		(23.64	%)
	2007		10.011		-		-		0.00	%		1.40	%		0.11	%
Focus Tier V with GMDB
	2009		9.336		8,360		78,042		0.00	%		1.10	%		21.56	%
	2008		7.680		-		-		0.00	%		1.10	%		(23.42	%)
	2007		10.029		-		-		0.00	%		1.10	%		0.29	%
Vanguard High Yield Bond
Focus Tier I
	2009		10.255		23,216		238,062		7.51	%		1.35	%		36.99	%
	2008		7.486		19,577		146,543		5.52	%		1.35	%		(22.99	%)
	2007		9.721		4,863		47,272		0.00	%		1.35	%		(2.79	%)
Focus Tier II
	2009		10.268		21,049		216,127		8.01	%		1.30	%		37.05	%
	2008		7.492		24,989		187,204		4.32	%		1.30	%		(22.95	%)
	2007		9.724		2,847		27,685		0.00	%		1.30	%		(2.76	%)
Focus Tier III
	2009		10.294		14,260		146,791		7.05	%		1.20	%		37.20	%
	2008		7.503		4,078		30,598		0.00	%		1.20	%		(22.89	%)
	2007		9.730		-		-		0.00	%		1.20	%		(2.70	%)
Focus Tier I with GMDB
	2009		10.228		5,032		51,467		6.07	%		1.45	%		36.85	%
	2008		7.474		2,274		16,999		4.89	%		1.45	%		(23.08	%)
	2007		9.716		-		-		0.00	%		1.45	%		(2.84	%)
Focus Tier II with GMDB
	2009		10.241		2,865		29,339		9.53	%		1.40	%		36.91	%
	2008		7.480		4,538		33,940		6.53	%		1.40	%		(23.04	%)
	2007		9.719		1,532		14,886		0.00	%		1.40	%		(2.81	%)
Focus Tier V with GMDB
	2009		10.321		15,018		154,998		8.19	%		1.10	%		37.34	%
	2008		7.515		17,452		131,158		8.15	%		1.10	%		(22.80	%)
	2007		9.735		17,452		169,905		0.00	%		1.10	%		(2.65	%)
Vanguard International
Focus Tier I
	2009		7.894		45,640		360,285		3.48	%		1.35	%		40.86	%
	2008		5.604		39,019		218,655		1.20	%		1.35	%		(45.66	%)
	2007		10.312		7,003		72,217		0.00	%		1.35	%		3.12	%
Focus Tier II
	2009		7.904		52,809		417,419		3.54	%		1.30	%		40.94	%
	2008		5.608		30,468		170,873		1.54	%		1.30	%		(45.63	%)
	2007		10.315		4,174		43,055		0.00	%		1.30	%		3.15	%
Focus Tier III
	2009		7.925		27,006		214,012		3.20	%		1.20	%		41.09	%
	2008		5.617		10,424		58,551		0.00	%		1.20	%		(45.58	%)
	2007		10.321		-		-		0.00	%		1.20	%		3.21	%
Focus Tier I with GMDB
	2009		7.874		6,626		52,170		3.36	%		1.45	%		40.73	%
	2008		5.595		4,745		26,546		0.63	%		1.45	%		(45.71	%)
	2007		10.306		-		-		0.00	%		1.45	%		3.06	%
Focus Tier II with GMDB
	2009		7.884		6,365		50,184		2.85	%		1.40	%		40.81	%
	2008		5.599		3,215		17,998		2.05	%		1.40	%		(45.69	%)
	2007		10.309		931		9,597		0.00	%		1.40	%		3.09	%

168

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Vanguard International (Continued)
Focus Tier V with GMDB
	2009	$	7.945		20,206	$	160,542		3.04	%		1.10	%		41.22	%
	2008		5.626		10,926		61,465		2.56	%		1.10	%		(45.52	%)
	2007		10.327		10,926		112,827		0.00	%		1.10	%		3.27	%
Vanguard Mid-Cap Index
Focus Tier I
	2009		7.339		77,366		567,792		1.54	%		1.35	%		38.50	%
	2008		5.299		63,131		334,555		1.14	%		1.35	%		(42.60	%)
	2007		9.232		12,299		113,544		0.00	%		1.35	%		(7.68	%)
Focus Tier II
	2009		7.349		80,542		591,867		1.63	%		1.30	%		38.56	%
	2008		5.304		68,527		363,435		0.75	%		1.30	%		(42.57	%)
	2007		9.235		6,845		63,211		0.00	%		1.30	%		(7.65	%)
Focus Tier III
	2009		7.368		46,850		345,172		1.66	%		1.20	%		38.70	%
	2008		5.312		25,233		134,039		1.40	%		1.20	%		(42.51	%)
	2007		9.240		8,639		79,822		0.00	%		1.20	%		(7.60	%)
Focus Tier I with GMDB
	2009		7.320		17,624		129,012		1.49	%		1.45	%		38.35	%
	2008		5.291		10,567		55,910		0.67	%		1.45	%		(42.66	%)
	2007		9.227		-		-		0.00	%		1.45	%		(7.73	%)
Focus Tier II with GMDB
	2009		7.330		6,107		44,769		2.05	%		1.40	%		38.43	%
	2008		5.295		10,048		53,206		1.41	%		1.40	%		(42.63	%)
	2007		9.229		3,660		33,777		0.00	%		1.40	%		(7.71	%)
Focus Tier V with GMDB
	2009		7.387		-		-		2.42	%		1.10	%		38.85	%
	2008		5.320		43,299		230,365		1.63	%		1.10	%		(42.46	%)
	2007		9.245		43,299		400,314		0.00	%		1.10	%		(7.55	%)
Vanguard REIT Index
Focus Tier I
	2009		6.299		23,412		147,456		4.70	%		1.35	%		27.41	%
	2008		4.944		19,669		97,233		1.76	%		1.35	%		(38.08	%)
	2007		7.985		1,910		15,246		0.00	%		1.35	%		(20.15	%)
Focus Tier II
	2009		6.307		28,953		182,595		4.81	%		1.30	%		27.49	%
	2008		4.947		23,542		116,471		1.54	%		1.30	%		(38.07	%)
	2007		7.988		1,834		14,649		0.00	%		1.30	%		(20.12	%)
Focus Tier III
	2009		6.323		11,509		72,770		4.74	%		1.20	%		27.61	%
	2008		4.955		6,085		30,152		0.00	%		1.20	%		(38.00	%)
	2007		7.992		-		-		0.00	%		1.20	%		(20.08	%)
Focus Tier I with GMDB
	2009		6.282		2,444		15,361		5.04	%		1.45	%		27.27	%
	2008		4.936		1,640		8,096		2.15	%		1.45	%		(38.15	%)
	2007		7.981		-		-		0.00	%		1.45	%		(20.19	%)
Focus Tier II with GMDB
	2009		6.290		3,979		25,028		2.77	%		1.40	%		27.33	%
	2008		4.940		1,806		8,921		3.70	%		1.40	%		(38.12	%)
	2007		7.983		955		7,624		0.00	%		1.40	%		(20.17	%)
Focus Tier V with GMDB
	2009		6.339		-		-		7.07	%		1.10	%		27.73	%
	2008		4.963		11,181		55,497		3.42	%		1.10	%		(37.94	%)
	2007		7.997		11,181		89,415		0.00	%		1.10	%		(20.03	%)

169

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Vanguard Total Bond Market Index
Focus Tier I
	2009	$	11.389		64,371	$	733,116		3.75	%		1.35	%		4.52	%
	2008		10.896		49,981		544,614		2.91	%		1.35	%		3.81	%
	2007		10.496		9,735		102,165		0.00	%		1.35	%		4.96	%
Focus Tier II
	2009		11.404		94,180		1,074,000		4.32	%		1.30	%		4.58	%
	2008		10.905		102,355		1,116,182		2.03	%		1.30	%		3.87	%
	2007		10.499		10,830		113,697		0.00	%		1.30	%		4.99	%
Focus Tier III
	2009		11.433		48,193		551,001		3.76	%		1.20	%		4.68	%
	2008		10.922		36,900		403,037		2.39	%		1.20	%		3.97	%
	2007		10.505		8,168		85,802		0.00	%		1.20	%		5.05	%
Focus Tier I with GMDB
	2009		11.360		18,865		214,301		3.82	%		1.45	%		4.42	%
	2008		10.879		9,310		101,295		2.00	%		1.45	%		3.71	%
	2007		10.490		-		-		0.00	%		1.45	%		4.90	%
Focus Tier II with GMDB
	2009		11.374		25,879		294,369		2.95	%		1.40	%		4.46	%
	2008		10.888		11,745		127,882		3.95	%		1.40	%		3.76	%
	2007		10.493		5,244		55,021		0.00	%		1.40	%		4.93	%
Focus Tier V with GMDB
	2009		11.463		96,229		1,103,028		3.74	%		1.10	%		4.79	%
	2008		10.939		60,397		660,709		4.29	%		1.10	%		4.07	%
	2007		10.511		60,397		634,821		0.00	%		1.10	%		5.11	%
Vanguard Total Stock Market Index
Focus Tier I
	2009		7.427		99,987		742,620		1.79	%		1.35	%		26.52	%
	2008		5.870		82,661		485,189		0.93	%		1.35	%		(38.12	%)
	2007		9.486		13,969		132,518		0.00	%		1.35	%		(5.14	%)
Focus Tier II
	2009		7.437		141,114		1,049,429		1.88	%		1.30	%		26.61	%
	2008		5.874		111,431		654,576		0.79	%		1.30	%		(38.10	%)
	2007		9.489		13,314		126,342		0.00	%		1.30	%		(5.11	%)
Focus Tier III
	2009		7.456		61,256		456,727		1.86	%		1.20	%		26.72	%
	2008		5.884		34,461		202,754		1.06	%		1.20	%		(38.02	%)
	2007		9.494		8,399		79,748		0.00	%		1.20	%		(5.06	%)
Focus Tier I with GMDB
	2009		7.408		24,688		182,888		1.70	%		1.45	%		26.42	%
	2008		5.860		12,235		71,704		0.62	%		1.45	%		(38.19	%)
	2007		9.481		-		-		0.00	%		1.45	%		(5.19	%)
Focus Tier II with GMDB
	2009		7.418		20,976		155,587		1.68	%		1.40	%		26.48	%
	2008		5.865		11,676		68,478		1.37	%		1.40	%		(38.16	%)
	2007		9.484		4,414		41,862		0.00	%		1.40	%		(5.16	%)
Focus Tier V with GMDB
	2009		7.475		-		-		2.71	%		1.10	%		26.85	%
	2008		5.893		52,408		308,830		1.53	%		1.10	%		(37.97	%)
	2007		9.500		52,408		497,869		0.00	%		1.10	%		(5.00	%)

170

Symetra Separate Account C

Notes to Financial Statements

6.  ACCUMULATION UNIT VALUES (Continued)

		As of December 31,						For the Year Ended December 31,
Sub-Account		Unit Value		Units Outstanding		Net Assets		Net Investment Income Ratio2			Expense Ratio3			Total Return4
Wanger USA
Spinnaker & Mainsail
	2009	$	38.470		8,453	$	325,191		0.00	%		1.40	%		40.25	%
	2008		27.430		10,298		282,484		0.00	%		1.40	%		(40.52	%)
	2007		46.120		11,198		516,406		0.00	%		1.40	%		3.92	%
	2006		44.382		11,987		531,993		0.24	%		1.40	%		6.38	%
	2005		41.721		15,840		660,882		0.00	%		1.40	%		9.71	%

  ¹  Reference Note 1 for current year name changes, reorganizations and commencement dates.

  ²  These amounts represent the dividends, excluding distributions of capital gains, received by the sub-account from the underlying mutual fund, net of management fees assessed by the fund manager, divided by the trading days average net assets. These ratios exclude those expenses, such as mortality and expense charges and asset related administration charges, that result in direct reductions in the unit values. The recognition of investment income by the sub-account is affected by the timing of the declaration of dividends by the underlying fund in which the sub-accounts invest.

  ³  These amounts represent the annualized contract expenses of the Separate Account, consisting primarily of mortality and expense charges, for the period indicated. The ratios include only those expenses that result in a direct reduction to unit values. Charges made directly to contract owner accounts through the redemption of units and expenses of the underlying fund are excluded.

  ⁴  These amounts represent the total return for the periods indicated, including changes in the value of the underlying funds, and reflect deductions for all items included in the expense ratio with the exception of fund reorganizations. Funds that have reorganized during the year present information through the time of reorganization. The total return ratio does not include any expenses assessed through the redemption of units, inclusion of these expenses in the calculation would result in a reduction in the total return presented. The total return is calculated for the period indicated or from the effective commencement date through the end of the reporting period.

171

Symetra Life Insurance Company

Financial Statements – Statutory Basis

As of December 31, 2009 and 2008

and Each of the Three Years in the Period Ended

December 31, 2009

Contents

Report of Independent Registered Public Accounting Firm	1
Financial Statements
Balance Sheets – Statutory Basis	2
Statements of Income – Statutory Basis	4
Statements of Changes in Capital and Surplus – Statutory Basis	5
Statements of Cash Flow – Statutory Basis	6
Notes to Financial Statements – Statutory Basis	8

Report of Independent Registered Public Accounting Firm

The Board of Directors

Symetra Life Insurance Company

We have audited the accompanying statutory-basis balance sheets of Symetra Life Insurance Company (the Company) as of December 31, 2009 and 2008, and the related statutory-basis statements of income, changes in capital and surplus, and cash flow for each of the three years in the period ended December 31, 2009. These financial statements are the responsibility of the Company’s management. Our responsibility is to express an opinion on these financial statements based on our audits.

We conducted our audits in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. We were not engaged to perform an audit of the Company’s internal control over financial reporting. Our audits included consideration of internal control over financial reporting as a basis for designing audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Company’s internal control over financial reporting. Accordingly, we express no such opinion. An audit also includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements, assessing the accounting principles used and significant estimates made by management, and evaluating the overall financial statement presentation. We believe that our audits provide a reasonable basis for our opinion.

As described in Note 1 to the financial statements, the Company presents its financial statements in conformity with accounting practices prescribed or permitted by the Washington State Office of the Insurance Commissioner (the Department), which practices differ from U.S. generally accepted accounting principles. The variances between such practices and U.S. generally accepted accounting principles and the effects on the accompanying financial statements are described in Note 1.

In our opinion, because of the effects of the matter described in the preceding paragraph, the financial statements referred to above do not present fairly, in conformity with U.S. generally accepted accounting principles, the financial position of Symetra Life Insurance Company at December 31, 2009 and 2008, or the results of its operations or its cash flows for each of the three years in the period ended December 31, 2009.

However, in our opinion, the financial statements referred to above present fairly, in all material respects, the financial position of Symetra Life Insurance Company at December 31, 2009 and 2008, and the results of its operations and its cash flows for each of the three years in the period ended December 31, 2009, in conformity with accounting practices prescribed or permitted by the Department.

As described in Note 1 to the financial statements, the Company changed its method of accounting for deferred income taxes, loan-backed and structured securities, and variable annuities in 2009.

/s/ Ernst & Young LLP

Seattle, Washington

April 16, 2010

1

Symetra Life Insurance Company

Balance Sheets – Statutory Basis

	December 31,
	2009		2008
Admitted assets
Cash and invested assets:
Bonds	$	14,480,111,022	$	12,313,790,055
Preferred stocks		63,178,945		560,058,638
Common stocks:
Affiliated		76,998,356		56,784,961
Nonaffiliated		149,905,772		103,709,066
Mortgage loans		1,177,741,609		990,327,460
Contract loans		73,649,137		74,962,718
Cash, cash equivalents, and short-term investments		51,800,983		297,912,055
Limited partnerships and other invested assets		84,552,891		82,412,574
Surplus notes		34,988,317		35,013,365
Receivable for securities sold		8,564,332		11,834,953
Options		1,776,506		2,274,242
Total cash and invested assets		16,203,267,870		14,529,080,087
Investment income, due and accrued		197,366,284		171,566,124
Uncollected premiums (net of loading of $(862,568) and $(1,088,268), respectively)		15,574,851		16,575,000
Deferred premiums (net of loading of $(23,629,207) and $(25,439,988), respectively)		49,426,271		52,112,984
Net deferred tax assets		81,083,639		42,803,128
Funds on deposit with reinsured company		72,806,886		69,734,732
Reinsurance recoverable		3,069,994		3,750,588
Current federal income tax recoverable		17,991,178		22,136,914
Affiliated receivables		26,274,052		7,564,667
Other receivables		10,776,170		9,268,837
Separate accounts assets		4,121,446,909		3,721,509,888
Total admitted assets	$	20,799,084,104	$	18,646,102,949

2

	December 31,
	2009			2008
Liabilities and capital and surplus
Liabilities:
Policy and contract liabilities:
Life and annuity reserves	$	12,263,550,219		$	10,579,100,464
Accident and health reserves		5,440,087			5,744,538
Policy and contract claims		114,040,050			125,369,724
Liability for deposit-type contracts		2,308,888,857			2,419,281,720
Unearned premiums and annuity considerations		2,090,469			1,440,313
Total policy and contract liabilities		14,694,009,682			13,130,936,759
Commissions and agents’ balances, due and accrued		3,235,013			1,840,325
General expenses and taxes, due and accrued		33,772,024			28,612,014
Transfers from separate accounts		(6,792,261	)		(6,913,278	)
Unearned investment income		1,645,923			1,642,047
Limited partnership liability		35,064,439			52,418,158
Secured benefit accounts liability		42,571,297			29,155,944
Other liabilities		73,511,575			90,671,873
Asset valuation reserve		119,046,098			112,732,854
Interest maintenance reserve		240,227,503			260,779,068
Affiliated payables		24,187,364			21,689,298
Payables for securities		1,723,433			22,053,340
Separate account liabilities		4,121,446,909			3,721,509,888
Total liabilities		19,383,648,999			17,467,128,290
Commitments and contingencies (Note 14)
Capital and surplus:
Common stock, $250 par value, 20,000 shares authorized, issued, and outstanding		5,000,000			5,000,000
Gross paid-in and contributed surplus		422,175,394			320,107,129
Special surplus funds		38,662,583			—
Unassigned funds		949,597,128			853,867,530
Total capital and surplus		1,415,435,105			1,178,974,659
Total liabilities and capital and surplus	$	20,799,084,104		$	18,646,102,949

See accompanying notes.

3

Symetra Life Insurance Company

Statements of Income – Statutory Basis

	Year Ended December 31,
	2009			2008			2007
Premiums and other revenues:
Premiums and annuity considerations	$	2,827,927,556		$	2,275,145,032		$	1,281,084,705
Net investment income		947,509,167			842,865,956			855,779,066
Amortization of interest maintenance reserve		19,827,540			20,076,298			19,671,954
Commissions, expense allowances, and reserve adjustments on reinsurance ceded		9,859,586			13,017,801			11,729,999
Other income		59,423,717			63,474,709			71,812,877
Total premiums and other revenues		3,864,547,566			3,214,579,796			2,240,078,601
Benefits:
Death benefits		89,733,669			86,203,940			89,685,921
Annuity benefits		292,545,460			281,167,396			283,075,873
Surrender and maturity benefits		817,581,684			839,814,104			1,476,216,175
Accidental and health and other benefits		434,436,285			452,183,808			377,097,237
Increase (decrease) in policy reserves		1,684,145,304			1,085,684,195			(562,287,938	)
Total benefits		3,318,442,402			2,745,053,443			1,663,787,268
Insurance expenses and other deductions:
Commissions		165,905,628			140,172,047			100,947,471
General insurance expenses		201,440,567			204,667,853			209,971,060
Net transfers to separate accounts		18,545,122			10,512,944			100,408,780
Total insurance expenses and other deductions		385,891,317			355,352,844			411,327,311
Gain from operations before dividends to policyholders, federal income taxes, and net realized capital losses		160,213,847			114,173,509			164,964,022
Dividends to policyholders		5,164			4,090			5,771
Gain from operations before federal income taxes and net realized capital losses		160,208,683			114,169,419			164,958,251
Federal income tax expense		30,741,842			14,949,198			29,742,518
Gain from operations before net realized capital losses		129,466,841			99,220,221			135,215,733
Net realized capital losses (net of federal income taxes and transfer to interest maintenance reserve)		(86,414,574	)		(62,512,058	)		(1,110,356	)
Net income	$	43,052,267		$	36,708,163		$	134,105,377

See accompanying notes.

4

Symetra Life Insurance Company

Statements of Changes in Capital and Surplus – Statutory Basis

	Common Stock		Gross Paid-In and Contributed Surplus		Special Surplus Funds		Unassigned Funds			Total Capital and Surplus
Balances as of January 1, 2007	$	5,000,000	$	270,107,129	$	—	$	991,114,832		$	1,266,221,961
Net income		—		—		—		134,105,377			134,105,377
Change in net unrealized capital gains		—		—		—		1,437,432			1,437,432
Change in net deferred income taxes		—		—		—		(12,788,307	)		(12,788,307	)
Change in nonadmitted assets		—		—		—		19,913,998			19,913,998
Change in asset valuation reserve		—		—		—		(17,492,279	)		(17,492,279	)
Dividends to Parent		—		—		—		(166,400,000	)		(166,400,000	)
Balances as of December 31, 2007		5,000,000		270,107,129		—		949,891,053			1,224,998,182
Net income		—		—		—		36,708,163			36,708,163
Change in net unrealized capital losses		—		—		—		(73,649,729	)		(73,649,729	)
Change in net deferred income taxes		—		—		—		13,881,238			13,881,238
Change in nonadmitted assets		—		—		—		(35,504,894	)		(35,504,894	)
Change in liability for reinsurance in unauthorized companies		—		—		—		(46,632	)		(46,632	)
Change in asset valuation reserve		—		—		—		62,588,331			62,588,331
Capital contribution from Parent		—		50,000,000		—		—			50,000,000
Dividends to Parent		—		—		—		(100,000,000	)		(100,000,000	)
Balances as of December 31, 2008		5,000,000		320,107,129		—		853,867,530			1,178,974,659
Net income		—		—		—		43,052,267			43,052,267
Change in net unrealized capital gains		—		—		—		35,609,079			35,609,079
Change in net deferred income taxes		—		—		—		9,019,416			9,019,416
Change in nonadmitted assets		—		—		—		14,497,469			14,497,469
Change in liability for reinsurance in unauthorized companies		—		—		—		46,632			46,632
Change in asset valuation reserve		—		—		—		(6,313,244	)		(6,313,244	)
Change in special surplus funds		—		—		38,662,583		—			38,662,583
Cumulative effect of changes in accounting principles		—		—		—		(182,021	)		(182,021	)
Capital contribution from Parent		—		102,068,265		—		—			102,068,265
Balances as of December 31, 2009	$	5,000,000	$	422,175,394	$	38,662,583	$	949,597,128		$	1,415,435,105

See accompanying notes.

5

Symetra Life Insurance Company

Statements of Cash Flow – Statutory Basis

	Year Ended December 31,
	2009			2008			2007
Operating activities
Premiums and annuity considerations collected	$	2,829,553,037		$	2,275,935,816		$	1,288,689,073
Net investment income received		877,282,001			807,208,087			842,884,833
Other income		68,707,369			76,114,769			82,272,816
Total cash provided by operating activities		3,775,542,407			3,159,258,672			2,213,846,722
Benefits and loss-related payments		(1,644,125,329	)		(1,635,093,046	)		(2,241,813,696	)
Transfers to separate accounts		26,130,354			36,154,554			68,069,982
Commissions, other expenses, and taxes paid		(356,129,406	)		(341,897,448	)		(302,869,172	)
Dividends to policyholders		(5,148	)		(5,130	)		(6,285	)
Federal income taxes paid		(5,268,304	)		(41,827,942	)		(71,448,209	)
Total cash used in operating activities		(1,979,397,833	)		(1,982,669,012	)		(2,548,067,380	)
Net cash provided by (used in) operating activities		1,796,144,574			1,176,589,660			(334,220,658	)
Investing activities
Investments sold or matured or repaid: Bonds		1,207,192,883			926,765,856			2,093,327,703
Stocks		34,311,504			35,659,580			239,095,195
Mortgage loans		73,384,865			79,459,133			78,257,907
Limited partnerships and other invested assets		—			22,721,841			35,156,862
Net losses on short-term investments		—			(18,439	)		(11,436	)
Total investments sold or matured		1,314,889,252			1,064,587,971			2,445,826,231
Cost of investments acquired: Bonds		(2,859,674,111	)		(1,548,277,835	)		(1,518,139,150	)
Stocks		(58,611,703	)		(71,220,711	)		(233,492,411	)
Mortgage loans		(262,989,063	)		(223,865,694	)		(133,419,891	)
Limited partnerships and other invested assets		(1,656,361	)		(14,130,542	)		(52,915,208	)
Miscellaneous proceeds (applications), net		(21,036,206	)		14,701,138			(585,486	)
Total cost of investments acquired		(3,203,967,444	)		(1,842,793,644	)		(1,938,552,146	)
Decrease in contract loans		1,313,580			1,967,213			2,067,541
Net cash (used in) provided by investing activities		(1,887,764,612	)		(776,238,460	)		509,341,626

6

Symetra Life Insurance Company

Statements of Cash Flow – Statutory Basis (continued)

	Year Ended December 31,
	2009			2008			2007
Financing activities
Net withdrawals on deposit-type contracts and other insurance liabilities	$	(110,392,880	)	$	(146,336,634	)	$	(61,014,681	)
Net transfers to Parent, subsidiaries, and affiliates		(16,211,318	)		(6,025,617	)		(9,136,367	)
Capital contribution from Parent		—			270,750			—
Dividends to Parent		—			(100,000,000	)		(166,400,000	)
Other cash (used) provided		(27,886,836	)		44,510,589			(253,065	)
Net cash used in financing activities		(154,491,034	)		(207,580,912	)		(236,804,113	)
Net (decrease) increase in cash and short-term investments		(246,111,072	)		192,770,288			(61,683,145	)
Cash, cash equivalents, and short-term investments, beginning of year		297,912,055			105,141,767			166,824,912
Cash, cash equivalents, and short-term investments, end of year	$	51,800,983		$	297,912,055		$	105,141,767
Supplemental disclosures of cash flow information
Noncash transactions during year:
Bonds and stocks – exchanges	$	214,638,538		$	44,226,030		$	164,114,997
Bonds – capital contribution to the Company from Parent		101,984,661			49,729,250			—
Bond interest converted to principal		32,698,772			29,345,926			34,745,670
Investment in limited partnership		10,695,949			4,202,340			22,943,048
Bonds and stocks – convertible bonds converted to common stock		5,604,665			1,043,438			79,343
Mortgage loans – refinances		1,477,716			11,969,423			16,543,742
Stocks – preferred stock converted to common stock		305,758			—			—
Bonds – bonds converted to warrants		253,771			—			—
Fixed assets – Capital Contribution to the Company from Parent		83,604			—			—
Stocks – spin-offs		77,930			949,849			—
Noncash litigation settlement		5,078			195,840			743,923
Bonds and stocks – transfer from Parent to the Company in exchange for other invested assets		—			79,031,953			—

See accompanying notes.

7

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis

December 31, 2009

1. Nature of Operations and Summary of Significant Accounting Policies

Nature of Operations

Symetra Life Insurance Company (the Company) is a stock life insurance company organized under the laws of the State of Washington. The Company offers group and individual insurance products and retirement products, including annuities marketed through benefits consultants, financial institutions, and independent agents and advisors, in all states (except New York) and the District of Columbia. The Company’s principal products as percentage of 2009 premium include fixed and variable deferred annuities (75.7%), medical stop-loss insurance (13.5%), single premium immediate annuities (4.6%), individual life insurance (4.2%), and bank owned life insurance (BOLI) (0.8%). The Company has two wholly owned subsidiaries: Symetra National Life Insurance Company and First Symetra National Life Insurance Company of New York.

The Company is a wholly owned subsidiary of Symetra Financial Corporation (the Parent), a Delaware Corporation. On January 27, 2010, the Parent completed the initial public offering (IPO) of its common stock. See Note 15 for additional ownership information.

Subsequent events have been considered through April 16, 2010, the date the financial statements were issued.

Basis of Presentation

The financial statements have been prepared in conformity with statutory accounting practices (SAP) prescribed or permitted by the Washington State Office of the Insurance Commissioner (the Department), which practices differ from U.S. generally accepted accounting principles (GAAP). Companies domiciled in the state of Washington prepare their statutory-basis financial statements in accordance with the National Association of Insurance Commissioners’ (NAIC) Accounting Practices and Procedures Manual, subject to any deviations prescribed or permitted by the Department.

Under Washington State Insurance code RCW 48.13.240(3), a mutual fund is classified as a miscellaneous investment and an investment in a single entity’s mutual fund is limited to no more than 1% of an insurer’s admitted assets. The Company, with the explicit permission of the Department, is permitted to invest up to 4% of its assets in a single entity’s mutual funds, as well

8

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

1. Nature of Operations and Summary of Significant Accounting Policies (continued)

as an unlimited amount of its assets in mutual funds listed on the NAIC’s most recent Mutual Fund Lists as U.S. Direct Obligations/Full Faith and Credit Exempt. As of December 31, 2009 and 2008, the Company held $94,870,630 or 0.46% and $321,314,340 or 1.72%, respectively, of admitted assets in a single entity’s mutual fund. The Company has no other permitted practices.

The preparation of financial statements requires management to make estimates and assumptions that affect the amounts reported in the financial statements and accompanying notes. Such estimates and assumptions could change in the future as more information becomes available, which could impact the amounts reported and disclosed herein.

The most significant estimates and assumptions include those used to determine the following: valuation of investments; the identification of other-than-temporary impairments (OTTI) of investments; the estimation of liabilities for policy and contract claims; and the recoverability of deferred tax assets (DTA). The recorded amounts reflect management’s best estimates, though actual results could differ. Management believes the amounts provided are appropriate.

Certain prior year amounts have been reclassified to conform to the current year presentation.

A description of the Company’s significant accounting policies, including the significant variances from GAAP, follows.

Recognition of Premiums and Annuity Considerations

Premiums are recognized annually on the policy anniversary for individual traditional life policies, consistent with the statutory reserving process. Premiums for universal life policies and annuity considerations with mortality and morbidity risk are recognized when received. Amounts received under deposit-type contracts with no life contingencies, including guaranteed interest and certain group annuity contracts, are recorded as liabilities when received. Group life and health premiums are recognized when due.

Under GAAP, individual traditional life premiums are recognized when due, while amounts received for universal life policies, annuity contracts, and pension deposit contracts are recorded as liabilities when received. Universal life GAAP premium revenue consists of policy charges made against the account balances.

9

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

1. Nature of Operations and Summary of Significant Accounting Policies (continued)

The Company estimates accrued retrospective premiums in accordance with the terms of each contract and records it as an adjustment to premium. For the years ended December 31, 2009, 2008, and 2007, the amount of net premiums written by the Company that are subject to retrospective rating features was $2,936,392, or 0.71%, $256,293, or 0.06%, and $252,125, or 0.07%, respectively, of the total net premiums written on the Company’s group health business.

The Company does not use managing general agents. Premiums written through third-party administrators totaled $35,797,810, $36,711,833, and $31,947,579 for the years ended December 31, 2009, 2008, and 2007, respectively.

Policy Acquisition Costs and Sales Inducements

The costs of acquiring and renewing business and sales inducements are expensed when incurred. Under GAAP, acquisition costs related to traditional life insurance, to the extent recoverable from future policy revenues, are deferred and amortized over the premium-paying period of the related policies using assumptions consistent with those used in computing policy benefit reserves. Acquisition costs for group accident and health insurance are amortized over the policy period of one year. For universal life insurance and deferred annuity contracts, to the extent recoverable from future gross profits, deferred policy acquisition costs (DAC) and sales inducements are amortized in proportion to the present value of expected gross profits from surrender charges and investment, mortality, and expense margins. For immediate annuities, a constant yield approach is used to amortize DAC.

Investments

The Company carries bonds and surplus notes not backed by other loans at amortized cost, using the scientific interest method of amortization. For all bonds, in or near default, reported values are at the lower of amortized cost or fair value.

Loan-backed bonds and structured securities, for which the collection of all contractual cash flows is probable, are carried at amortized cost using the scientific interest method, including anticipated prepayments at the date of purchase. Prepayment assumptions for loan-backed bonds and structured securities are obtained from external sources or internal estimates, and are consistent with the current interest rate and economic environment. The retrospective adjustment method is used to value these securities. Yields and the related amortization schedules are adjusted for changes in estimated cash flows. For loan-backed bonds and structured securities, in or near default, reported values are at the lower of amortized cost or fair value.

10

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

1. Nature of Operations and Summary of Significant Accounting Policies (continued)

Redeemable preferred stocks that have characteristics of debt securities and are rated as medium quality or better (NAIC designations 1-3) are reported at cost or amortized cost. All other redeemable preferred stocks are reported at the lower of cost, amortized cost, or fair value.

Changes in admitted asset carrying amounts of bonds and preferred stocks are credited or charged directly to unassigned funds.

Common stocks are reported at fair value and the related net unrealized capital gains (losses) are reported in unassigned funds, net of related deferred income taxes.

Under GAAP, fixed-maturity investments (bonds, surplus notes, and redeemable preferred stocks) and certain marketable equity securities (primarily nonredeemable preferred stocks and certain mutual fund assets) are classified as available-for-sale and carried at fair value with the changes in unrealized gains (losses) recorded directly to accumulated other comprehensive income (loss), or AOCI, net of related DAC and deferred income taxes.

Also under GAAP, common stocks are classified as trading marketable equity securities and carried at fair value with the impact of changes in fair value recorded in net realized investment gains (losses).

The Company’s insurance subsidiaries are included in affiliated common stocks and are carried at their underlying statutory equity, as described in Section (3iiA) of the SVO Practices and Procedures Manual. Changes in the carrying value of subsidiaries are credited or charged directly to unassigned surplus. The Company owns no shares, either directly or indirectly, of the Parent. Under GAAP, the accounts and operations of the subsidiaries are consolidated.

The Company determines the carrying value of common stock of its affiliate Berkshire Hathaway, Inc. using the market valuation method as described in Section 3(i) of the SVO Practices and Procedures Manual.

When the collectability of interest income for bonds is considered doubtful, any accrued but uncollectible interest income is reversed against investment income in the current period. The Company then places the securities on nonaccrual status, and they are not restored to accrual status until all delinquent interest and principal is paid.

11

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

1. Nature of Operations and Summary of Significant Accounting Policies (continued)

Investments are considered to be impaired when a decline in fair value is judged to be other-than-temporary. The Company’s review of investment securities includes both quantitative and qualitative criteria. Quantitative criteria include the length of time and amount that each security is in an unrealized loss position and, for bonds, whether the issuer is in compliance with the terms and covenants of the security. See Note 2 for additional discussion about the Company’s process for identifying and recording OTTI.

Mortgage loans on real estate are carried at the amount of outstanding principal balances. The maximum percentage the Company allows of any one loan to the value of its security at the time of the loan, exclusive of insured, guaranteed, or purchase money mortgages, is 75%. The maximum actual percentage of any one loan to value was 65.6% and 75.0% for loans funded during the years ending December 31, 2009 and 2008, respectively. Fire insurance is required on all properties covered by mortgage loans in an amount at least equal to 100% of the insurable value of the improvements. The Company considers a mortgage loan impaired when it is probable that the Company will be unable to collect principal and interest amounts due according to the contractual terms of the mortgage loan agreement. For mortgage loans that the Company determines to be impaired, the Company charges the difference between the estimated fair value of the collateral and the recorded investment in the mortgage loan as a realized capital loss, and a new cost basis is established. The Company accrues interest income on impaired loans to the extent that it is deemed collectible and the loan continues to perform under its original or restructured terms. If a mortgage loan has any investment income due and accrued that is 180 days past due and collectible, the investment income will continue to accrue, but all interest related to the loan will be reported as a nonadmitted asset.

Under GAAP, mortgage loans are carried at outstanding principal balances, less a valuation allowance.

Contract loans are carried at unpaid principal balance.

Cash, cash equivalents, and short-term investments represent highly liquid investments with original maturities of one year or less and are carried at cost, which approximates fair value. Under GAAP, short-term investments consists of highly liquid debt instruments with original maturities of greater than three months and less than 12 months, and cash consists of demand bank deposits and highly liquid short-term investments with original maturities of three months or less.

12

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

1. Nature of Operations and Summary of Significant Accounting Policies (continued)

Investments in limited partnerships consisted of investments in affordable housing projects and state tax credit funds which were initially recorded at cost and subsequently carried at amortized cost. As of December 31, 2009, the Company was invested in 12 limited partnership interests, two of which were entered into during 2009. As of December 31, 2008, the Company was invested in 12 limited partnership interests related to tax-sheltered affordable housing projects and state tax credit funds, three of which were entered into during 2008. Annual amortization is based on the proportion of tax benefits received in the current year to total estimated tax benefits to be allocated to the Company and is recorded in change in net unrealized capital gains (losses) in the statements of change in capital and surplus. A liability is also recorded for future equity contributions at the present value of these future contributions, which are considered unconditional and legally binding.

Net realized capital gains (losses) are determined on a specific-identification basis.

The Company participated in a securities lending program whereby securities were loaned to third parties, primarily to major brokerage firms. The Company discontinued its securities lending activities in 2009. Under this program, the loaned securities remained in exclusive control of the Company. The collateral provided by the transferee was in the form of invested assets and represented a minimum of 102% of the fair value of the loaned securities. If at any time the fair value of the collateral was less than 100% of the fair value of the loaned securities, the transferee was obligated to deliver additional collateral, the fair value of which, together with the fair value of all the collateral equaled at least 102% of the fair value of the loaned securities. The collateral assets were restricted and were not available for general use by the Company. The fair value of the collateral deposited by the borrower was $0 and $88,115,675 as of December 31, 2009 and 2008, respectively. Until 2009, the separate account participated in the general account securities lending program. The fair value of the collateral deposited by the borrower within the separate account was $0 and $17,598,540 as of December 31, 2009 and 2008, respectively.

Nonadmitted Assets

Certain assets designated as “nonadmitted” and other assets not specifically identified as an admitted asset within the NAIC Accounting Practices and Procedures Manual are excluded from the accompanying statutory-basis balance sheets and are charged directly to unassigned funds.

13

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

1. Nature of Operations and Summary of Significant Accounting Policies (continued)

Under GAAP, such assets are included in the balance sheets. Nonadmitted assets are comprised principally of certain receivables for securities, DTAs, fixed assets, software, accounts and notes receivable, and intangible assets from acquisitions.

Reinsurance

Reinsurance premiums and claims are accounted for on bases consistent with those used in accounting for the original policies issued and the terms of the reinsurance contracts. Premiums, claims, and the reserves for policy and contract liabilities are reported net, rather than gross, of reinsured amounts. Under GAAP, assets and liabilities related to reinsurance ceded contracts are reported on a gross basis.

Benefit Reserves

Life, annuity, and accident and health benefit reserves are developed by actuarial methods and are based on published tables using statutorily specified interest rates and valuation methods that provide, in the aggregate, reserves that are greater than or equal to the minimum or guaranteed policy cash values or the amount required by the Department.

Tabular interest, tabular less actual reserve released, and tabular cost have been determined by formula. Tabular interest on funds not involving life contingencies is calculated on an exact basis for group annuities and as the product of the valuation interest rate and the mean amount of funds held at the beginning and end of the year for other lines of business. The Company waives deduction of deferred fractional premiums upon the death of life and annuity policy insureds and returns any premium beyond the date of death. Surrender values on policies do not exceed the corresponding benefit reserves.

Additional reserves are established if the results of cash flow testing under various interest rate scenarios indicate the need for such reserves, or if the net premiums exceed the gross premiums on any insurance in force. For substandard lives, either extra premium is charged, or the gross premium for a rated age is charged; mean reserves are determined by computing the regular mean reserve for the plan at any rated age and, in addition, holding one-half of any extra premium charge for the year. Liabilities related to other policyholders’ funds left on deposit are equal to the account balances.

14

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

1. Nature of Operations and Summary of Significant Accounting Policies (continued)

The Company does not use anticipated investment income as a factor in the premium deficiency calculation.

Included in benefit reserves are deposit-type contracts, which relate to contracts that do not incorporate risk from the death or disability of policyholders. Deposits and withdrawals received on these contracts are recorded as a direct increase or decrease to the liability balance, and are not reflected as premiums, benefits, or changes in reserves in the statements of income.

GAAP requires that policy reserves be calculated on estimated expected experience or actual account balances.

Policy and Contract Claims

Claims reserves on life and accident and health policies represent the estimated ultimate net cost of all reported and unreported claims at the balance sheet date. The Company discounts its long-term disability claims reserves using disability tables and discount rates (generally approximately 5%) approved by the Department. The reserves for reported but unpaid claims incurred date are estimated using individual valuations and statistical analyses. The liability held for pending life insurance claims is equal to the face amount of the policy. The reserves for claims incurred but not reported (IBNR) are based on expected loss ratios, claims paying completion patterns, and historical experience. The Company reviews estimates for reported but unpaid claims and IBNR quarterly. Any necessary adjustments are reflected in the statements of income. If expected loss ratios increase or expected claims paying completion patterns extend, the IBNR claim liability increases.

Under GAAP, the liability for pending claims for universal life and BOLI products equals the net amount at risk, which is the face amount of the policy, less the account value.

Asset Valuation Reserve

The Asset Valuation Reserve (AVR) provides a valuation allowance for invested assets and is calculated based on a formula prescribed by the NAIC. This reserve acts to mitigate the effects of potential losses in the event of default by issuers of certain invested assets. Changes in the AVR are reflected directly in unassigned funds. No such reserve exists under GAAP.

15

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

1. Nature of Operations and Summary of Significant Accounting Policies (continued)

Interest Maintenance Reserve

The Interest Maintenance Reserve (IMR) defers after-tax capital realized gains (losses) resulting from the effect of changes in the general level of interest rates on the disposal of fixed-income investments. These deferrals are amortized to income, using the grouped method, over the approximate remaining years to maturity of the securities sold. The grouped method is based on groupings of gains and losses, in five-year bands. Under GAAP, realized capital gains (losses) are reported in the consolidated statements of income on a pre-tax basis in the period in which the assets are sold.

Federal Income Taxes

The Company is the parent of a consolidated group filing a life consolidated federal income tax return. The method of allocation of federal income tax expense between the companies in the consolidated group is subject to a written agreement approved by the Company’s Board of Directors. Allocation is based upon separate return calculations, except that current credit for tax credits and net operating loss carryforwards are determined on the basis of the consolidated group. The provision for federal income taxes is based on amounts determined to be payable as a result of current year operations. Intercompany balances are settled quarterly.

Deferred federal income taxes are provided for differences between the book and tax bases of assets and liabilities. In determining admissibility under Statement of Statutory Accounting Principles (SSAP) No. 10R, Income Taxes (SSAP No. 10R), DTAs are subject to a statutory valuation allowance if, based on the weight of available evidence, it is more likely than not that some portion or all of the gross DTAs will not be realized. The gross DTAs remaining after the application of a statutory valuation allowance, if any, are admitted following the standards of this SSAP. Remaining DTAs after application of the admissibility tests are nonadmitted. Changes in deferred taxes are recorded directly to unassigned funds.

Under GAAP, deferred tax assets are recognized only to the extent that it is probable that future tax profits will be available. A valuation allowance is established where deferred tax assets cannot be recognized. Changes in deferred taxes are reported in the consolidated statements of income.

16

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

1. Nature of Operations and Summary of Significant Accounting Policies (continued)

Claims Adjustment Expenses

The liability balance for unpaid accident and health claims adjustment expenses, as of December 31, 2009 and 2008, was $982,000 and $1,228,000, respectively. The Company incurred $2,637,837 and paid $2,883,837 of claim adjustment expenses in the current year, of which $724,460 was attributable to insured or covered events of prior years. For the year ended December 31, 2008, $2,419,533 of claims adjustment expense was incurred and $2,462,553 was paid, of which $575,810 was attributable to insured or covered events of prior year. The Company did not take into account estimated salvage and subrogation in its determination of the liability for unpaid claims adjustment expenses.

Separate Accounts

The Company administers segregated asset accounts (separate accounts) for variable annuity and variable life policyholders. The assets of these separate accounts, which consist of bonds and stocks, are reported at fair value. The liabilities of these separate accounts represent reserves established to meet withdrawal and future benefit payment provisions of contracts with the policyholders. The assets of the separate accounts are not subject to liabilities arising out of any other business the Company may conduct. Investment risks associated with fair value changes are borne by the policyholders.

The Company also administers separate accounts for BOLI policyholders. The assets of these separate accounts, which consist of bonds and surplus notes, are held at amortized cost. The liabilities of these separate accounts represent reserves established to meet withdrawal and future benefit payment provisions of contracts with the policyholders. The assets are legally segregated and are not subject to claims that arise out of the Company’s other business activities.

The operations of all separate accounts, excluding investment gains (losses) allocable solely to the policyholders, are combined with the general account of the Company in the statements of income under the appropriate captions. Transactions such as premium deposits, surrenders, and withdrawals are offset by a corresponding increase or decrease in net transfers to the separate accounts.

17

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

1. Nature of Operations and Summary of Significant Accounting Policies (continued)

For variable annuity contracts with guaranteed minimum death benefits (GMDB), the Company contractually guarantees total deposits made to the contract, less any partial withdrawals, in the event of death. The Company offers three types of GMDB contracts consisting of return of premium and two versions of ratchet, which are evaluated every fifth and eighth year, respectively. The ratchet reset benefit is equal to the immediately preceding GMDB or is “stepped up” to the account value on the evaluation date, if higher. The Company reinsures nearly all of the GMDB risk on its individual variable contracts. Therefore, the recorded liability is not material.

Under GAAP, separate account assets and liabilities reported on the balance sheets consist of the fair value of the funds invested on behalf of the Company’s variable annuity and variable life policyholders. Net investment income and net realized and unrealized investment gains and losses accrue directly to the policyholders and are not included in the Company’s revenue.

Reconciliation of Statutory-Basis Amounts to GAAP Amounts

A reconciliation of net income and capital and surplus of the Company, as determined in accordance with SAP to amounts determined in accordance with GAAP, is as follows:

	Net Income Year Ended December 31,
	2009			2008			2007
Statutory-basis amounts	$	43,052,267		$	36,708,163		$	134,105,377
Add (deduct) adjustments:
Investments		(1,540,055	)		(147,841,558	)		(61,336,825	)
Reserves		7,809,855			59,128,716			86,181,318
Policy acquisition costs		86,362,285			78,686,020			41,223,098
Federal income taxes		(22,274,160	)		9,035,456			(50,522,396	)
Intangible assets and goodwill		5,585,284			5,585,284			5,611,534
Other, net		12,377,309			6,400,410			12,267,847
		88,320,518			10,994,328			33,424,576
GAAP-basis amounts	$	131,372,785		$	47,702,491		$	167,529,953

18

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

1. Nature of Operations and Summary of Significant Accounting Policies (continued)

	Total Capital and Surplus December 31,
	2009			2008			2007
Statutory-basis amounts	$	1,415,435,105		$	1,178,974,659		$	1,224,998,182
Add (deduct) adjustments:
Investments		696,658,992			(696,920,850	)		797,124,614
Reserves		(820,875,060	)		(958,256,498	)		(867,055,777	)
Policy acquisition costs		240,745,202			238,977,087			131,727,066
Federal income taxes		81,196,345			565,890,353			125,180,433
Intangible assets and goodwill		(11,632,437	)		(17,217,721	)		(22,803,006	)
Nonadmitted assets and other, net		120,503,101			160,548,506			105,375,017
		306,596,143			(706,979,123	)		269,548,347
GAAP-basis amounts	$	1,722,031,248		$	471,995,536		$	1,494,546,529

New Accounting Pronouncements

In accordance with the changes adopted by the NAIC’s Hybrid Risk-Based Capital (RBC) Working Group, the Company changed its categorization of hybrid securities as of January 1, 2009. Under the new guidance, hybrid securities are reported as bonds with no reduction to their NAIC designation. These hybrid securities, also referred to as trust preferred securities and capital securities, were previously reported as preferred stocks and their NAIC designation was reduced by one in the calculation of the asset valuation reserve. The total carrying value of hybrid securities reported as preferred stocks as of December 31, 2008 was $497,050,594 and were not reclassified in 2008. As required by SSAP No. 32, Investments in Preferred Stock, hybrid securities classified as preferred stocks with NAIC designations 4 to 6 were previously reported at the lower of amortized cost or fair value. This resulted in gross unrealized losses of $20,405,419, decreasing surplus as of December 31, 2008. Under the new guidance, hybrid securities are accounted for under SSAP No. 26, Bonds, excluding Loan-backed and Structured Securities, which requires that securities are reported at amortized cost except for those with a NAIC designation 6, which are reported at lower of amortized cost or fair value. This resulted in a release of the prior year’s unrealized loss, which had a positive current year impact of $20,405,419 to surplus. The impact is reflected net of tax in the change in net unrealized capital gains in the statement of changes in capital and surplus.

19

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

1. Nature of Operations and Summary of Significant Accounting Policies (continued)

The Company adopted SSAP No. 43R, Loan-backed and Structured Securities (SSAP No. 43R) as of September 30, 2009. This SSAP substantively revises SSAP No. 43 and supersedes SSAP 98, Treatment of Cash Flows When Quantifying Changes in Valuation and Impairments and paragraph 13 of SSAP No. 99, Accounting for Certain Securities Subsequent to an Other-Than-Temporary Impairment. This SSAP revises valuation and impairment requirements to be based on the present value of cash flows expected to be collected for securities in which the Company has the intent and ability to hold, but does not expect to recover the entire amortized cost basis, and requires impaired securities that the Company intends to sell to be recorded at fair value. The cumulative effect on adoption of SSAP No. 43R was $182,021, net of taxes.

The Company adopted SSAP No. 10R, as of December 31, 2009. This SSAP substantively revises SSAP No. 10, Income Taxes, to allow the admission of adjusted gross DTAs expected to be realized within three years of the balance sheet date, an increase from the prior recovery period of one year. In addition, SSAP No. 10R increases the limit for admissibility from the current 10% of adjusted capital and surplus to 15% for qualifying companies. Upon adoption of SSAP No. 10R, the Company recorded an adjustment of $38,662,583 as an increase to special surplus funds. See Note 10 – Income Taxes for further information.

The Company adopted Actuarial Guideline XLIII, CARVM for Variable Annuities, as of December 31, 2009. This Guideline replaces Actuarial Guideline XXXIV, Variable Annuity Minimum Guaranteed Death Benefit Reserves, and Actuarial Guideline XXXIX, Reserves for Variable Annuities with Guaranteed Living Benefits. This Guideline establishes a principles based approach for determining reserves for variable annuities. The reserves established as of December 31, 2009 under Actuarial Guideline XLIII are $4,088,554 higher than the reserves that would have been held for the same period under the prior guidelines. The impact of adopting Actuarial Guideline XLIII was reflected in the current period statement of income.

Accounting Pronouncements Not Yet Adopted

In December 2009, the NAIC issued SSAP No. 100, Fair Value Measurements. This SSAP defines fair value, establishes a framework for measuring fair value and establishes fair value disclosure requirements. This SSAP is effective for the December 31, 2010 annual financial statements, with interim and annual financial statement reporting thereafter. The Company does not expect the adoption to have a material impact on the Company’s balance sheets, statements of income, or statements of changes in capital and surplus.

20

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

2. Investments

The book/adjusted carrying value, gross unrealized capital gains (losses), and fair value of investments in bonds are summarized as follows:

	Book/Adjusted Carrying Value		Gross Unrealized Gains		Gross Unrealized Losses			Fair Value
Bonds as of December 31, 2009:
U.S. government and agencies	$	24,551,768	$	2,657,309	$	(92,667	)	$	27,116,410
Foreign governments and agencies		17,422,769		2,579,654		—			20,002,423
States, territories, and possessions		5,410,000		68,206		(27,498	)		5,450,708
Political subdivisions		234,181,376		5,194,824		(8,520,782	)		230,855,418
Special revenue and assessments		241,943,917		6,745,434		(12,072,804	)		236,616,547
Industrial and miscellaneous		9,680,672,649		605,145,677		(177,805,277	)		10,108,013,049
Hybrid securities		547,488,553		4,925,256		(94,212,518	)		458,201,291
Mortgage-backed/asset-backed securities		3,728,439,990		136,921,180		(140,792,128	)		3,724,569,042
Total bonds	$	14,480,111,022	$	764,237,540	$	(433,523,674	)	$	14,810,824,888

	Book/Adjusted Carrying Value		Gross Unrealized Gains		Gross Unrealized Losses			Fair Value
Bonds as of December 31, 2008:
U.S. government and agencies	$	80,470,561	$	3,850,466	$	(881,097	)	$	83,439,930
Foreign governments and agencies		11,834,156		996,853		—			12,831,009
States, territories, and possessions		13,317,707		3,621,462		—			16,939,169
Political subdivisions		228,725,235		2,643,058		(25,456,947	)		205,911,346
Special revenue and assessments		240,015,546		11,250,921		(16,944,074	)		234,322,393
Industrial and miscellaneous		8,209,325,543		213,876,911		(925,707,873	)		7,497,494,581
Mortgage-backed/asset-backed securities		3,530,101,307		99,885,094		(297,572,877	)		3,332,413,524
Total bonds	$	12,313,790,055	$	336,124,765	$	(1,266,562,868	)	$	11,383,351,952

21

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

2. Investments (continued)

The following tables show gross unrealized losses and fair values of bonds, aggregated by investment category, and present separately those securities that have been in a continuous unrealized loss position for less than 12 months and for 12 months or more.

	Less Than 12 Months					12 Months or More					Total
	Fair Value		Gross Unrealized Losses			Fair Value		Gross Unrealized Losses			Fair Value		Gross Unrealized Losses
Bonds as of December 31, 2009:
U.S. government and agencies	$	2,172,000	$	(92,667	)	$	—	$	—		$	2,172,000	$	(92,667	)
States, territories, and possessions		—		—			572,502		(27,498	)		572,502		(27,498	)
Political subdivisions		32,156,115		(910,929	)		57,022,960		(7,609,853	)		89,179,075		(8,520,782	)
Special revenue and assessments		3,978,249		(13,146	)		111,533,870		(12,059,658	)		115,512,119		(12,072,804	)
Industrial and miscellaneous		941,848,520		(25,723,825	)		1,317,196,742		(152,081,452	)		2,259,045,262		(177,805,277	)
Hybrid securities		38,255,046		(974,540	)		392,046,244		(93,237,978	)		430,301,290		(94,212,518	)
Mortgage-backed/asset-backed securities		344,978,082		(7,497,667	)		866,284,040		(133,294,461	)		1,211,262,122		(140,792,128	)
Total bonds	$	1,363,388,012	$	(35,212,774	)	$	2,744,656,358	$	(398,310,900	)	$	4,108,044,370	$	(433,523,674	)

	Less Than 12 Months					12 Months or More					Total
	Fair Value		Gross Unrealized Losses			Fair Value		Gross Unrealized Losses			Fair Value		Gross Unrealized Losses
Bonds as of December 31, 2008:
U.S. government and agencies	$	48,364,000	$	(881,097	)	$	—	$	—		$	48,364,000	$	(881,097	)
Political subdivisions		133,072,566		(23,394,699	)		17,411,264		(2,062,248	)		150,483,830		(25,456,947	)
Special revenue and assessments		94,769,118		(12,621,127	)		39,519,024		(4,322,947	)		134,288,142		(16,944,074	)
Industrial and miscellaneous		3,401,670,336		(438,430,489	)		1,573,413,047		(487,277,384	)		4,975,083,383		(925,707,873	)
Mortgage-backed/asset-backed securities		885,757,735		(159,246,094	)		551,506,461		(138,326,783	)		1,437,264,196		(297,572,877	)
Total bonds	$	4,563,633,755	$	(634,573,506	)	$	2,181,849,796	$	(631,989,362	)	$	6,745,483,551	$	(1,266,562,868	)

22

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

2. Investments (continued)

The Company reviewed all its investments with unrealized losses at the end of 2009 and 2008 in accordance with the impairment policy. The Company’s evaluation determined, after the recognition of OTTI, that the remaining declines in fair value were temporary, as it did not intend to sell the securities prior to maturity at an amount below the carrying value. For loan-backed bonds and structured securities, the Company expects to recover the entire amortized cost basis. As of December 31, 2009 and 2008, the Company had $284,552,135 and $481,685,327, respectively, of gross unrealized losses for a period of 12 months or more related to investment-grade bonds. Unrealized losses on investment-grade bonds are principally related to changes in interest rates or changes in the issuer and the sector-related credit spreads since the securities were acquired.

As of December 31, 2009 and 2008, the Company held below-investment-grade bonds with fair values of $979,302,663 and $623,753,877, respectively, and book adjusted carrying value of $1,051,507,986 and $878,437,468, respectively. These holdings amounted to 6.6% and 5.5% of the Company’s investments in bonds at fair value as of December 31, 2009 and 2008, respectively.

Industries that represented more than 10% of the total below-investment-grade bonds as of December 31, 2009, were financials at 29.20%, materials at 20.83%, and utilities at 10.68%. As of December 31, 2008, the industries were materials at 19.38%, consumer discretionary at 15.75%, telecommunication services at 15.11%, utilities at 14.51%, and financials at 11.20%.

As of December 31, 2009 and 2008, the majority of the Company’s mortgage-backed securities were classified as prime. Based on a review of the characteristics of the underlying mortgage loan pools, such as credit scores and financial ratios, the Company classified $102,430,840 and $113,073,894 of mortgage-backed securities as Alt-A as of December 31, 2009 and 2008, respectively, as each has overall collateral credit quality between prime and subprime. These securities represented 2.82% and 3.52% of the fair value of total mortgage-backed securities at December 31, 2009 and 2008, respectively. Of the securities classified as Alt-A, 38.4% and 100% had Standard and Poor’s (S&P) credit rating of AAA as of December 31, 2009 and 2008, respectively.

23

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

2. Investments (continued)

In addition the Company classified $73,191 and $383,110 as subprime, representing 0.0% and 0.01% of the fair value of total mortgage-backed securities as of December 31, 2009 and 2008, respectively. The subprime mortgage-backed securities were issued from a dedicated second-lien shelf, which the Company considers to be a subprime risk, regardless of credit score or other metrics. The Company does not own any securities from dedicated subprime shelves. The subprime securities had a S&P credit rating of B as of both December 31, 2009 and 2008.

The Company’s investments in asset-backed securities, which are included in mortgage-backed securities, had fair values of $93,109,812 and $121,460,808 as of December 31, 2009 and 2008, respectively.

The book/adjusted carrying value and fair value of bonds as of December 31, 2009, by contractual maturity, are presented below. Expected maturities may differ from contractual maturities because borrowers may have the right to call or prepay obligations with or without prepayment penalties.

	Book/Adjusted Carrying Value		Fair Value
Years to maturity:
One or less	$	427,291,446	$	434,896,234
Over one through five		2,568,638,033		2,686,930,885
Over five through ten		3,296,873,369		3,466,865,472
Over ten		4,458,868,184		4,497,563,255
Mortgage-backed/asset-backed securities		3,728,439,990		3,724,569,042
Total	$	14,480,111,022	$	14,810,824,888

Certain bonds with book/adjusted carrying values of $5,640,026 and $5,564,474 were on deposit with various regulatory authorities as of December 31, 2009 and 2008, respectively.

24

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

2. Investments (continued)

The book/adjusted carrying value, gross unrealized gains (losses), and fair value of investments in preferred stocks are summarized as follows:

	Book/Adjusted Carrying Value		Gross Unrealized Gains		Gross Unrealized Losses			Fair Value
Preferred stocks as of December 31, 2009:
Industrial and miscellaneous	$	63,178,945	$	97,458	$	(13,055,656	)	$	50,220,747
Total preferred stocks	$	63,178,945	$	97,458	$	(13,055,656	)	$	50,220,747
Preferred stocks as of December 31, 2008:
Hybrid securities	$	497,050,594	$	3,788,916	$	(128,071,848	)	$	372,767,662
Industrial and miscellaneous		63,008,044		1,682,593		(16,378,007	)		48,312,630
Total preferred stocks	$	560,058,638	$	5,471,509	$	(144,449,855	)	$	421,080,292

The cost, gross unrealized gains (losses), and fair value of investments in common stocks are summarized as follows:

	Cost		Gross Unrealized Gains		Gross Unrealized Losses			Fair Value
Common stocks as of December 31, 2009:
Affiliated	$	73,405,552	$	3,657,305	$	(64,501	)	$	76,998,356
Nonaffiliated		138,028,239		26,945,953		(15,068,420	)		149,905,772
Total common stocks	$	211,433,791	$	30,603,258	$	(15,132,921	)	$	226,904,128
Common stocks as of December 31, 2008:
Affiliated	$	51,888,098	$	4,963,572	$	(66,709	)	$	56,784,961
Nonaffiliated		151,781,801		3,658,087		(51,730,822	)		103,709,066
Total common stocks	$	203,669,899	$	8,621,659	$	(51,797,531	)	$	160,494,027

25

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

2. Investments (continued)

The following tables show the gross unrealized losses and fair values of stocks, aggregated by investment category and length of time that individual securities have been in a continuous unrealized loss position for less than 12 months and for 12 months or more.

	Less Than 12 Months					12 Months or More					Total
	Fair Value		Gross Unrealized Losses			Fair Value		Gross Unrealized Losses			Fair Value		Gross Unrealized Losses
Preferred stocks as of December 31, 2009:
Industrial and miscellaneous	$	11,391,070	$	(3,487,681	)	$	38,284,895	$	(9,567,975	)	$	49,675,965	$	(13,055,656	)
Total preferred stocks	$	11,391,070	$	(3,487,681	)	$	38,284,895	$	(9,567,975	)	$	49,675,965	$	(13,055,656	)
Preferred stocks as of December 31, 2008:
Hybrid securities	$	50,690,297	$	(18,392,539	)	$	257,222,018	$	(109,679,309	)	$	307,912,315	$	(128,071,848	)
Industrial and miscellaneous		14,109,375		(10,890,625	)		6,140,597		(5,487,382	)		20,249,972		(16,378,007	)
Total preferred stocks	$	64,799,672	$	(29,283,164	)	$	263,362,615	$	(115,166,691	)	$	328,162,287	$	(144,449,855	)
	Less Than 12 Months					12 Months or More					Total
	Fair Value		Gross Unrealized Losses			Fair Value		Gross Unrealized Losses			Fair Value		Gross Unrealized Losses
Common stocks as of December 31, 2009:
Affiliated	$	831,358	$	(4,704	)	$	315,456	$	(59,797	)	$	1,146,814	$	(64,501	)
Unaffiliated		15,500,630		(1,854,134	)		27,003,817		(13,214,286	)		42,504,447		(15,068,420	)
Total common stocks	$	16,331,988	$	(1,858,838	)	$	27,319,273	$	(13,274,083	)	$	43,651,261	$	(15,132,921	)
Common stocks as of December 31, 2008:
Affiliated	$	308,544	$	(66,709	)	$	—	$	—		$	308,544	$	(66,709	)
Unaffiliated		66,305,305		(42,082,060	)		14,336,613		(9,648,762	)		80,641,918		(51,730,822	)
Total common stocks	$	66,613,849	$	(42,148,769	)	$	14,336,613	$	(9,648,762	)	$	80,950,462	$	(51,797,531	)

As of December 31, 2009, financial institutions, U.S. federal government, industrials, and utilities represented 21.7%, 14.8%, 12.5%, and 10.8%, respectively, of the Company’s investments in bonds and common and preferred stocks at fair value.

As of December 31, 2008, financial institutions, U.S. federal government, utilities, and industrials represented 23.4%, 17.3%, 12.4%, and 10.2%, respectively, of the Company’s investments in bonds and common and preferred stocks at fair value.

No other industry represented more than 10% of the fair value of bonds and common and preferred stocks as of December 31, 2009 or 2008.

26

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

2. Investments (continued)

The Company’s net investment income is summarized as follows:

	Year Ended December 31,
	2009		2008		2007
Income:
Bonds	$	880,694,383	$	747,119,617	$	756,250,370
Preferred stocks		4,536,700		39,285,940		42,499,635
Common stocks		3,521,506		2,270,223		1,607,214
Mortgage loans		68,059,970		59,919,328		53,723,155
Contract loans		4,370,616		4,465,185		4,723,426
Cash, cash equivalents, and short-term investments		974,871		5,254,483		10,972,388
Other invested assets		2,563,938		1,911,326		2,204,682
Other interest income		1,455,776		894,906		2,028,319
Total investment income		966,177,760		861,121,008		874,009,189
Expenses:
Investment expenses		18,499,063		18,123,937		18,130,171
Investment taxes, licenses, and fees, excluding federal income taxes		168,019		131,115		99,952
Interest expense		1,511		—		—
Total investment expenses		18,668,593		18,255,052		18,230,123
Net investment income	$	947,509,167	$	842,865,956	$	855,779,066

There have been no bonds that have not produced income for the last 12 months as of December 31, 2009 and 2008.

27

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

2. Investments (continued)

The proceeds from sales and maturities of investments in bonds, the related capital gains (losses) on bonds, and other invested assets are as follows:

	Year Ended December 31,
	2009			2008			2007
Bonds:
Proceeds from sales	$	282,274,692		$	259,819,468		$	1,598,969,062
Proceeds from maturities		924,918,191			666,946,388			494,358,641
Total bonds	$	1,207,192,883		$	926,765,856		$	2,093,327,703
Bonds:
Gross realized capital gains on sales	$	14,607,855		$	31,057,934		$	90,897,189
Gross realized capital losses on sales		(9,427,009	)		(3,473,764	)		(15,398,860	)
Net realized capital gains on sales		5,180,846			27,584,170			75,498,329
Other:
Net gains (losses) on dispositions other than sales		(213,235	)		(1,460,213	)		2,215,154
Impairments		(90,591,628	)		(70,664,672	)		(12,352,309	)
Total gains (losses) on bonds		(85,624,017	)		(44,540,715	)		65,361,174
Preferred stocks		—			(143,929	)		7,490,994
Common stocks		4,174,538			1,365,112			9,431,470
Impairments – preferred and common stocks		(26,110,977	)		(1,380,573	)		(773,554	)
Mortgage loans		(2,190,049	)		—			—
Other invested assets		(982,735	)		12,956,728			2,693,787
Options		2,266,839			(3,902,858	)		(2,441,796	)
Short-term investments		—			(18,439	)		(11,436	)
Realized capital gains (losses) before federal income taxes and transfer to IMR		(108,466,401	)		(35,664,674	)		81,750,639
Amount transferred to IMR		724,025			(18,521,121	)		(49,719,359	)
Federal income tax benefit (expense)		21,327,802			(8,326,263	)		(33,141,636	)
Net realized capital losses	$	(86,414,574	)	$	(62,512,058	)	$	(1,110,356	)

28

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

2. Investments (continued)

Securities for which cost or amortized cost exceeds fair value are considered underwater. The Company’s review of its underwater bonds and preferred and common stocks for OTTI includes an analysis of the gross unrealized losses by three categories of securities: (i) securities where the estimated fair value has declined and remained below cost or amortized cost by less than 20%, (ii) securities where the estimated fair value has declined and remained below cost or amortized cost by 20% or more for less than six months, and (iii) securities where the estimated fair value has declined and remained below cost or amortized cost by 20% or more for six months or longer. While all securities are monitored for impairment, the Company’s experience indicates that the first category does not represent a significant risk of impairment and, often, fair values recover over time as the factors that caused the declines improve. In times of economic turbulence, such as those of 2008 and 2009, securities in category (ii) represent a significant risk. Securities in category (iii) are always considered to represent a significant risk. The Company performs a qualitative analysis by issuer to identify securities in category (i) that should be further evaluated for OTTI.

If the value of a security falls into category (ii) or (iii), the Company analyzes the decrease in fair value to determine whether it is an other-than-temporary decline in value. To make this determination for each security, the Company considers, among other factors:

• Extent and duration of the decline in fair value below cost or amortized cost;

• The financial condition and near-term prospects of the issuer of the security, including any specific events that may affect its operations, earnings potential, or compliance with terms and covenants of the security;

• Changes in the financial condition of the security’s underlying collateral;

• Any downgrades of the security by a rating agency;

• Any reduction or elimination of dividends or nonpayment of scheduled interest payments;

• Other indications that a credit loss has occurred; and

• The Company’s intent to sell the security or whether the Company has the intent and ability to retain the investment for a period of time sufficient to recover the amortized cost basis.

29

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

2. Investments (continued)

Based on its analysis, the Company makes a judgment as to whether the loss is other-than-temporary. If the loss is other-than-temporary, the Company records an impairment charge within net realized capital losses in the statements of income in the period that the Company makes the determination. In addition, any impaired investments where the Company has either made a decision to sell prior to maturity at an amount below the carrying value or the Company has assessed it does not have the intent and ability to retain the investment for a period of time sufficient to recover the amortized cost basis are recorded as an OTTI.

Prior to September 2009, the Company’s process for determining OTTI was similar for all bonds including loan-backed and structured securities. Loan-backed and structured securities were also evaluated by comparing the carrying value to estimated undiscounted future cash flows. In September 2009, the Company implemented new accounting guidance for OTTI related to loan-backed bonds and structured securities. These securities are evaluated further to determine if the decline is other-than-temporary. When an OTTI has occurred due to the Company’s intent to sell the security or the Company has assessed it does not have the intent and ability to retain the security until sufficient time to recover the amortized cost basis, the investments are written down and carried at fair value. When an OTTI has occurred because the Company does not expect to recover the entire cost basis, even if the Company has the intent and ability to hold, the investments are written down and carried at the present value of cash flows expected to be collected, discounted at the effective rate immediately prior to the recognition of the OTTI. For periods subsequent to the loss recognition, the prospective adjustment methodology is used to value the security and the new amortized cost basis is not adjusted for subsequent recoveries in fair value.

To determine the recovery value of a loan-backed or structured security, the Company performs an analysis related to the underlying issuer including, but not limited to, the following:

• Discounted cash flow analysis based on the current and future cash flows the Company expects to recover;

• Level of creditworthiness;

• Delinquency ratios and loan-to-value ratios;

30

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

2. Investments (continued)

• Average cumulative collateral loss, vintage year, and level of subordination;

• Susceptibility to fair value fluctuations due to changes in the interest rate environment;

• Susceptibility to reinvestment risk in cases where market yields are lower than the book yield earned;

• Susceptibility to reinvestment risk in cases where market yields are higher than the book yields earned and the Company’s expectation of the sale of such security; and

• Susceptibility to variability of prepayments.

During 2009, the Company recorded impairment charges on bonds and common and preferred stocks totaling $116,702,605. The largest impairments were from investments in the financials industry totaling $40,084,857, or 34.3%; in the consumer discretionary industry, totaling $27,948,224, or 23.9%; in the materials industry totaling $19,714,633, or 16.9%; and in the industrial industry totaling $12,876,979, or 11.0%. During 2008, the Company recorded impairment charges on bonds and common and preferred stocks totaling $72,045,245. The largest impairments were from investments in the paper-related industry totaling $12,678,816, or 17.6%; in the financials industry totaling $8,371,816, or 11.62%; and in commercial printing industry totaling $7,792,727, or 10.82%. During 2007, the Company recorded impairments of $13,125,863 primarily on investments in the paper-related industry totaling $4,838,030, or 36.9%, and in the publishing industry totaling $2,131,397, or 16.24%.

OTTI for loan-backed and structured securities recognized for the year ended December 31, 2009 are summarized as follows:

	Amortized Cost Basis Before OTTI		OTTI Recognized				Book/Adjusted Carrying Value		Fair Value at Time of OTTI
			Interest		Non-interest
Aggregate present value of cash flows	$	206,425,914	$	—	$	13,298,551	$	193,127,363	$	156,392,630

31

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

2. Investments (continued)

Loan-backed and structured securities with a prior OTTI held by the Company at December 31, 2009 are as follows:

CUSIP	Book/Adjusted Carrying Value Amortized Cost before Current Period OTTI		Recognized OTTI		Amortized Cost after OTTI		Fair Value at Time of OTTI
02149DAJ8	$	16,391,766	$	2,189,207	$	14,202,559	$	11,468,675
02149DAJ8		13,715,616		640,244		13,075,372		10,559,854
05952FAE3		34,336,848		390,549		33,946,299		33,946,299
05952FAE3		25,175,155		642,313		24,532,842		22,951,044
05952FAE3		19,698,937		2,526,144		17,172,793		18,832,928
12545CAD2		14,406,280		1,533,639		12,872,641		10,332,854
12613YAB5		6,290,487		154,707		6,135,780		3,770,309
12667F6C4		9,322,882		174,129		9,148,753		4,396,129
126694W46		13,353,227		774,476		12,578,751		8,729,940
126694W79		16,159,185		1,537,877		14,621,308		6,568,734
126694X52		8,081,983		434,688		7,647,295		4,693,807
161630BX5		2,450,849		133,732		2,317,117		2,011,107
32056FAD4		9,270,761		1,184,873		8,085,888		8,326,062
395386AP0		15,517,666		370,956		15,146,710		11,310,570
46630UAC8		12,841,287		1,252,402		11,588,885		9,517,990
9292272X3		2,304,087		111,446		2,192,641		1,738,159
Total	$	219,317,016	$	14,051,382	$	205,265,634	$	169,154,461

As of December 31, 2009 and 2008, the Company’s investment portfolio included $1,177,741,609 and $990,327,460, respectively, of mortgage loan investments, constituting approximately 5.7%, and 5.3%, respectively, of total admitted assets. These loans are secured by first mortgage liens on income-producing commercial real estate, primarily in the retail, industrial, and office building sectors. The weighted-average loan to value (LTV) ratio, which is a loan’s carrying amount divided by its appraised value at loan inception, was 48.8% and 54.7% for loans funded during 2009 and 2008, respectively. The weighted-average LTV ratio for the Company’s entire mortgage portfolio was 53.2% and 51.2% as of December 31, 2009 and 2008, respectively. The majority of the properties are located in the western United States, with 28.4% and 26.8% of the total in California with carrying values totaling $333,933,294 and $265,852,737, respectively, and with 18.8% and 21.3% of the total in Washington with carrying

32

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

2. Investments (continued)

values totaling $221,278,852 and $211,218,869, respectively, as of December 31, 2009 and 2008. As of December 31, 2009, there was one nonperforming loan and as of December 31, 2008, there were no nonperforming loans. The maximum and minimum lending rates for mortgage loans made during 2009 were 7.94% and 6.00%, respectively.

The Company had one impaired mortgage loan without an allowance for credit losses with a book value of $1,670,000 as of December 31, 2009 and no impaired loans as of December 31, 2008. The average recorded investment in impaired loans was $835,000 and $0 as of December 31, 2009 and 2008, respectively. The Company had no investments in restructured loans as of December 31, 2009 and 2008.

The Company held no mortgage loans with interest more than 180 days past due as of December 31, 2009 or 2008. During 2009, the Company reduced interest rates on outstanding mortgage loans by 0.50% on one loan with a carrying value totaling $565,245. During 2008, the Company reduced interest rates on outstanding mortgage loans by 1.865% on one loan with a carrying value totaling $1,054,616 and by 1.125% on another loan with a carrying value of $348,650. As of December 31, 2009 and 2008, there were no taxes, assessments, or amounts advanced that had not been repaid and had not been included in the mortgage loan total, and there were no outstanding liens.

The Company’s limited partnership interests related to low-income housing tax credits (LIHTC) as of December 31, 2009, are as follows:

LIHTC Investment	Remaining Years of Unexpired Credits*	Remaining Required Holding Period
MMA Financial Institutional Tax Credits XXXII	11 Years	15 Years
MMA Financial Institutional Tax Credits XXX	9 Years	14 Years
Centerline Corporate Partners XXX, LP	9 Years	13 Years
PNC Multifamily Capital Institutional Fund XXXV	11 Years	15 Years
Centerline Corporate Partners XXI, LP	8 Years	9 Years
Centerline Corporate Partners XXXV, LP	10 Years	15 Years
USA Institutional Tax Credit Fund LXXII, LP	12 Years	16 Years

* Does not include carryforward provisions in Internal Revenue Code Section 39.

33

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

2. Investments (continued)

These properties are not currently subject to any regulatory review. The Company’s aggregate investment in LIHTC does not exceed 10% of its admitted assets. Commitments for future capital contributions related to LIHTC investments are disclosed in Note 14 – Commitments and Contingencies.

3. Derivative Financial Instruments

The Company has a closed block of fixed indexed annuity (FIA) product that credits the policyholders’ accounts based on a percentage of the gain in the S&P 500 Index. In connection with this product, the Company has a hedging program with the objective to hedge the exposure to changes in the S&P 500 Index. This program consists of buying S&P 500 Index options. Although the Company uses index options to hedge the equity return component of the FIA, the options do not qualify as hedging instruments according to the criteria in SSAP No. 86, Accounting for Derivatives and Hedging Activities. Accordingly, the assets are recorded at fair value as free-standing derivative assets or options in other invested assets. These options have limited off-balance sheet risk related to the risk of default by the counterparty. The current credit exposure of the Company’s derivative contracts is limited to the fair value at the reporting date. Credit risk is managed by entering into transactions with creditworthy counterparties and obtaining collateral where appropriate and customary. The Company also attempts to minimize its exposure to credit risk through the use of various credit monitoring techniques. All of the net credit exposure for the Company from derivative contracts is with investment-grade counterparties. The Company’s options’ book value totaled $2,370,000 and $1,424,000 as of December 31, 2009 and 2008, respectively. Unrealized capital gains (losses) of $(593,494) and $850,242 were recorded in unassigned funds as of December 31, 2009 and 2008, respectively. The Company recognized pre-tax gains (losses) on expired, sold, or exercised options of $2,266,839, $(3,902,858), and $(2,441,796) for the years ended December 31, 2009, 2008 and 2007, respectively, which are recorded as realized capital gains (losses) in the statements of income.

4. Fair Value Disclosures

Included in various investment-related line items in the financial statements are certain financial instruments carried at fair value. Other financial instruments are periodically measured at fair value, such as when impaired, or, for certain bonds and preferred stocks when carried at the lower of cost or fair value.

34

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

4. Fair Value Disclosures (continued)

The Company uses the same pricing methodology and sources as utilized for obtaining GAAP fair values, which reflects the price at which the security would sell in an arms-length transaction between a willing buyer and seller in possession of the same information.

In accordance with GAAP, the Company determines the fair value of its financial instruments based on the fair value hierarchy, which requires an entity to maximize its use of observable inputs and minimize the use of unobservable inputs when measuring fair value. The Company has categorized its financial instruments, based on the priority of the inputs to the valuation technique, into the three-level hierarchy. The fair value hierarchy gives the highest priority to quoted prices in active markets for identical assets or liabilities (Level 1) and the lowest priority to unobservable inputs (Level 3). The level in the fair value hierarchy within which the fair value measurement falls is determined based on the lowest-level input that is significant to the fair value measurement. The Company’s financial assets recorded at fair value on the balance sheets are categorized as follows:

• Level 1 – Unadjusted quoted prices in active markets for identical instruments. Primarily consists of financial instruments whose value is based on quoted market prices, such as common and preferred stocks, and actively traded mutual fund investments.

• Level 2 – Quoted prices for similar instruments in active markets; quoted prices for identical or similar instruments in markets that are not active; and model-derived valuations whose inputs are observable or whose significant value drivers are observable.

This level includes those financial instruments that are valued using industry-standard pricing methodologies, models, or other valuation methodologies. These models are primarily industry-standard models that consider various inputs, such as interest rate, credit spread, and foreign exchange rates for the underlying financial instruments. All significant inputs are observable, derived from observable information in the marketplace, or are supported by observable levels at which transactions are executed in the market place.

• Level 3 – Instruments whose significant value drivers are unobservable. This comprises financial instruments for which fair value is estimated based on industry-standard pricing methodologies and internally developed models utilizing significant inputs not based on or corroborated by readily available market information. In limited circumstances, this

35

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

4. Fair Value Disclosures (continued)

category may also utilize non-binding broker quotes. This category primarily consists of certain less liquid bonds, including corporate private placement securities, and common stocks where the Company cannot corroborate the significant valuation inputs with market observable data.

The following tables provides information about the Company’s financial assets measured and reported at fair value under the valuation hierarchy, as described above, on a recurring basis. The Company has no financial liabilities accounted for at fair value on a recurring basis.

	As of December 31, 2009
	Level 1		Level 2		Level 3		Total		Level 3 Percent
Assets at Fair Value
Common stock – affiliated	$	4,744,984	$	—	$	—	$	4,744,984	—	%
Common stock – nonaffiliated		149,647,309		—		258,463		149,905,772	0.02
Other invested assets		—		—		893,211		893,211	0.09
Options		—		—		1,776,506		1,776,506	0.18
Separate account assets 1		840,022,056		—		—		840,022,056	—
Total assets at fair value	$	994,414,349	$	—	$	2,928,180	$	997,342,529	0.29	%
	As of December 31, 2008
	Level 1		Level 2		Level 3		Total		Level 3 Percent
Assets at Fair Value
Common stock – affiliated	$	3,127,222	$	—	$	—	$	3,127,222	—	%
Common stock – nonaffiliated		103,529,266		—		179,800		103,709,066	0.02
Other invested assets		—		—		157,970		157,970	0.02
Options		—		—		2,274,242		2,274,242	0.28
Separate account assets 1		716,088,048		—		—		716,088,048	—
Total assets at fair value	$	822,744,536	$	—	$	2,612,012	$	825,356,548	0.32	%

Note  ¹: Reflects only variable separate account assets.

36

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

4. Fair Value Disclosures (continued)

The following table provides information about the Company’s financial assets measured and reported at fair value on a non-recurring basis.

	As of December 31, 2009
	Level 1		Level 2		Level 3		Total
Bonds – NAIC designation 6 and OTTI	$	—	$	16,277,059	$	11,097,101	$	27,374,160
Preferred Stocks – NAIC designation 4-6		117,000		—		—		117,000
	$	117,000	$	16,277,059	$	11,097,101	$	27,491,160
	As of December 31, 2008
	Level 1		Level 2		Level 3		Total
Bonds – NAIC designation 6 and OTTI	$	—	$	4,827,750	$	7,280,000	$	12,107,750
Preferred Stocks – NAIC designation 4-6		138,038		30,966,283		—		31,104,321
	$	138,038	$	35,794,033	$	7,280,000	$	43,212,071

37

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

4. Fair Value Disclosures (continued)

The following table summarizes the book/adjusted carrying value and corresponding fair values of financial instruments subject to fair value disclosure requirements.

	December 31, 2009
	Book/Adjusted Carrying Value		Fair Value
Assets
Bonds	$	14,480,111,022	$	14,810,824,888
Preferred stocks		63,178,945		50,220,747
Common stocks		226,904,128		226,904,128
Mortgage loans		1,177,741,609		1,161,931,645
Other invested assets		119,541,208		116,173,258
Options		1,776,506		1,776,506
Separate accounts assets		4,121,446,909		4,173,564,674
Liabilities
Annuity and deposit contracts		12,637,449,275		13,589,791,145
	December 31, 2008
	Book/Adjusted Carrying Value		Fair Value
Assets
Bonds	$	12,313,790,055	$	11,383,351,952
Preferred stocks		560,058,638		421,080,292
Common stocks		160,494,027		160,494,027
Mortgage loans		990,327,460		907,606,345
Other invested assets		117,425,939		113,780,762
Options		2,274,242		2,274,242
Separate accounts assets		3,721,509,888		3,530,312,682
Liabilities
Annuity and deposit contracts		10,946,483,794		10,729,250,646

38

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

4. Fair Value Disclosures (continued)

The fair value of bonds, preferred stocks, common stocks, and separate account assets is based on the fair value hierarchy.

The fair values of mortgage loans are determined by discounting the projected future cash flows using the current rate at which loans would be made to borrowers with similar credit ratings and for similar maturities.

Carrying value is a reasonable estimate of fair value for cash, cash equivalents, short-term investments, contract loans, other receivables, and other liabilities.

Fair value of investments in limited partnerships is estimated based on the discounted cash flows over the remaining life of the tax credits.

The fair value of annuities and deposit contracts is estimated by discounting projected cash flows using rates that reflect the claims paying ability of the Company for the same remaining maturities.

Other insurance-related financial instruments are exempt from the disclosure requirements of SSAP No. 27, Disclosure of Information about Financial Instruments with Off-Balance-Sheet Risk, Financial Instruments with Concentrations of Credit Risk and Disclosures about Fair Value of Financial Instruments.

5. Premium and Annuity Considerations Deferred and Uncollected

The deferred and uncollected life insurance premiums and annuity considerations are as follows:

	December 31, 2009						December 31, 2008
Type	Gross			Net of Loading			Gross			Net of Loading
Ordinary – new business	$	2,544,736		$	649,670		$	927,094		$	162,237
Ordinary – renewal		19,984,503			46,371,344			22,307,862			49,600,975
Group life		(531,080	)		(531,080	)		(531,318	)		(531,318	)
Total	$	21,998,159		$	46,489,934		$	22,703,638		$	49,231,894

39

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

6. Reinsurance

The Company protects itself from excessive losses by reinsuring with other companies. Reinsurance contracts do not relieve the Company of its obligations to policyholders. A contingent liability exists in the event a reinsurance company is unable to meet its obligations to the Company. The Company evaluates the financial condition of its reinsurers to minimize the exposure to losses from reinsurers’ insolvencies. The Company is not aware of any of its major reinsurers currently experiencing material financial difficulties. The Company analyzes amounts recoverable from reinsurers according to the credit ratings of its reinsurers. Of the total amounts due from reinsurers as of December 31, 2009 and 2008, 99.6% and 99.7%, respectively, was with reinsurers rated A- or higher by A.M. Best.

The Company has catastrophic loss coverage for its group life, individual life, and aggregate stop-loss medical business.

For group life business, the Company has reinsurance coverage in the case of a catastrophic event resulting in at least three accidental death claims. The coverage has a deductible that varies based on the amount of insurance in force.

For individual life business, the Company has reinsurance coverage in the case of a catastrophic event resulting in at least three accidental death claims. The coverage has a deductible that varies based on average policy size and amount of insurance in force. The Company also has reinsurance agreements that limit the maximum claim on a single individual to $500,000. The reinsurance agreements vary by product and policy issue year. Most of the reinsurance reserve credit relates to life reserves and is covered by coinsurance agreements where the reinsurer reimburses the Company based on a percentage, which ranges from 50% to 85%, as specified in the reinsurance contracts.

For aggregate stop-loss medical reinsurance, the Company has 100% reinsurance coverage on all policies not underwritten by Medical Risk Managers, a wholly-owned subsidiary of the Company’s Parent, for the portion of aggregate losses above $1,000,000 and up to $10,000,000. For these policies, amounts are automatically 100% reinsured if the specific excess loss deductible is less than or equal to $500,000. If the specific excess loss deductible is greater than $500,000, the group will be reinsured on a facultative basis. The liability of the reinsurer shall not exceed $9,000,000 for each policy. The Company’s aggregate stop-loss business underwritten by Medical Risk Managers is reinsured 40% for the portion of aggregate losses up to $2,000,000.

40

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

6. Reinsurance (continued)

The Company also reinsures 100% of its group long-term and short-term disability business, except for the short-term disability income insurance sold within the limited benefit medical plan, which is not reinsured. The reinsurer is responsible for paying all claims.

Reserve credits taken for all ceded reinsurance were $349,332,787 and $327,231,000 as of December 31, 2009 and 2008, respectively.

The Company, in the ordinary course of business, has two coinsurance agreements in-force with related parties, Wilton Reassurance Company and White Mountains Reinsurance Company of America, affiliates of the Company’s Parent. Of the total reserve credits taken as of December 31, 2009 and 2008, $8,775,151 and $6,958,786, respectively, related to Wilton Reassurance Company. Reserve credits taken related to White Mountains Reinsurance Company were $9,012 and $0 as of December 31, 2009 and 2008, respectively. Except as mentioned prior, neither the Company nor any of its related parties control, either directly or indirectly, any other reinsurers with which the Company conducts business. No policies issued by the Company have been reinsured with a foreign company that is controlled, either directly or indirectly, by a party not primarily engaged in the business of insurance.

No new agreements were executed, nor were existing agreements amended, to include policies or contracts that were in force or that had existing reserves established by the Company as of the effective date of the agreement during the years ended December 31, 2009 and 2008. The Company has no reinsurance agreements for which reserve credits have been taken, under which the reinsurers may cancel the coverage at their discretion.

During 2009, 2008, and 2007, the Company did not commute any ceded reinsurance, nor did it write off any uncollectible reinsurance.

The Company does not have any reinsurance agreements in effect in which the amount of losses paid or accrued would result in a payment to the reinsurer of amounts that, in the aggregate and allowing for offset of mutual credits from other reinsurance agreements with the same reinsurer, exceed the total premiums collected under the reinsured policies.

41

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

6. Reinsurance (continued)

The effects of reinsurance on premiums and annuity considerations are as follows:

	Year Ended December 31,
	2009			2008			2007
Premiums and annuity considerations
Direct:
Accident and health premiums	$	426,955,711		$	448,440,758		$	390,139,699
Life insurance premiums		189,943,901			192,468,746			209,992,492
Annuity premiums		2,272,884,599			1,702,640,198			741,937,867
Total direct premiums		2,889,784,211			2,343,549,702			1,342,070,058
Assumed:
Accident and health premiums		445,412			611,093			—
Life insurance premiums		169,002			156,306			131,593
Annuity premiums		5,200			78,879			110,204
Total assumed premiums		619,614			846,278			241,797
Ceded:
Accident and health premiums		(12,603,924	)		(14,106,260	)		(10,315,678	)
Life insurance premiums		(48,993,370	)		(54,245,228	)		(49,854,431	)
Annuity premiums		(878,975	)		(899,460	)		(1,057,041	)
Total ceded premiums		(62,476,269	)		(69,250,948	)		(61,227,150	)
Total premiums and annuity considerations	$	2,827,927,556		$	2,275,145,032		$	1,281,084,705

Ceded reinsurance reduced the Company’s claims by $47,051,811, $42,117,186, and $42,679,372 for 2009, 2008, and 2007, respectively.

42

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

7. Life and Annuity Reserves

The Company’s annuity reserves and deposit fund liabilities, including those held in separate account liabilities, are summarized as follows:

	December 31, 2009					December 31, 2008
	Amount			Percent of Total		Amount			Percent of Total
Subject to discretionary withdrawal (with adjustment):
With fair value adjustment	$	365,562,583		2.6	%	$	380,456,965		3.2	%
At book value, less surrender charge of 5% or more		4,197,852,087		30.4			2,508,477,298		20.9
At fair value		750,765,592		5.5			641,090,157		5.3
Total with adjustment or at fair value		5,314,180,262		38.5			3,530,024,420		29.4
Subject to discretionary withdrawal (without adjustment):
At book value (minimal or no charge or adjustment)		2,387,297,131		17.3			2,388,775,042		19.9
Not subject to discretionary withdrawal		6,099,747,332		44.2			6,095,873,085		50.7
Total annuity actuarial reserves and deposit fund liabilities, before reinsurance		13,801,224,725		100.0	%		12,014,672,547		100.0	%
Reinsurance ceded		(5,102,026	)				(5,515,066	)
Total net annuity actuarial reserves and deposit fund liabilities	$	13,796,122,699				$	12,009,157,481

As of December 31, 2009 and 2008, the Company had $2,295,145,274 and $2,726,808,207, respectively, of insurance in force for which the gross premiums were less than the net premiums according to the standard valuation established by the Department. Reserves to cover this difference were $30,225,574 and $36,578,353 as of December 31, 2009 and 2008, respectively, and were included in aggregate reserves.

43

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

7. Life and Annuity Reserves (continued)

Symetra Life Insurance Company issues variable annuities with GMDBs. None of the Company’s variable annuities have guaranteed living benefits. The following table identifies the statement values of the variable annuities reserved for under Actuarial Guideline 43 (AG43) as of December 31, 2009:

Product	General Account			Separate Account		Total Statutory Reserves		Fund Value
MainSail	$	1,604,782		$	3,112,768	$	4,717,550	$	4,615,355
Resource A		(978	)		6,402,104		6,401,126		6,402,104
Resource B		9,431			58,710,843		58,720,274		58,710,843
Group VA		83,665,529			215,041,551		298,707,080		298,618,154
Focus		(55,521	)		15,692,846		15,637,325		16,684,861
Spinnaker Advisor		17,022,152			52,654,984		69,677,136		67,965,376
Spinnaker Group		116,694			146,332		263,026		263,027
Spinnaker		241,514,583			354,749,414		596,263,997		599,079,985
Spinnaker Plus		55,287,734			26,525,907		81,813,641		81,884,071
Spinnaker Enhanced		3,502,625			4,369,240		7,871,865		8,238,642
Spinnaker Choice		698,099			2,472,232		3,170,331		3,320,518
WM CVA		7,461,594			10,887,371		18,348,965		18,230,775
Total	$	410,826,724		$	750,765,592	$	1,161,592,316	$	1,164,013,711

The total net amount at risk on this block is approximately $36,000,000 as of December 31, 2009, of which approximately $27,000,000 is reinsured. Over 95% of the net amount at risk on the individual contracts is reinsured.

The AG43 provision is calculated based on a total asset requirement as determined by the 70% conditional tail expectation (CTE) of the greatest present value of pre-tax projected accumulated deficiencies under 999 stochastic scenarios, or the standard scenario amount, if higher. The standard scenario amount is computed based on a pre-determined formula and under a set of defined assumptions as outlined in AG43 Appendix 3; the standard scenario amount is equal to the base adjusted reserve plus the greatest present value of the negative of the accumulated net revenues minus the value of aggregate reinsurance, subject to the cash value floor.

None of the 999 scenarios projected negative surplus amounts. Therefore, the Company’s AG43 reserves as of December 31, 2009 are equal to the standard scenario amount. The Company tested the impact of a 25% increase in expenses and the standard scenario amount was still higher than the result of the expense sensitivity test.

44

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

7. Life and Annuity Reserves (continued)

The Company did not record an opening balance adjustment under the adoption of AG43.

The Company did not request or receive permission from the Department to grade in the reserves calculated under AG43.

8. Policy and Contract Claims

The following table provides a reconciliation of the beginning and ending reserve balances for policy and contract claims, net of reinsurance recoverables:

	Year Ended December 31,
	2009		2008		2007
Policy and contract claims liability, beginning of the year	$	125,369,724	$	105,114,352	$	114,940,894
Add provision for claims, net of reinsurance, occurring in:
Current year		372,152,414		371,122,639		301,178,369
Prior years		1,673,042		4,437,460		(3,338,355	)
Net incurred losses during the year		373,825,456		375,560,099		297,840,014
Deduct payments for claims, net of reinsurance, occurring in:
Current year		293,436,897		281,276,334		234,448,475
Prior years		91,718,233		74,028,393		73,218,081
Net claim payments during the current year		385,155,130		355,304,727		307,666,556
Policy and contract claims liability, end of year	$	114,040,050	$	125,369,724	$	105,114,352

The Company uses estimates in determining its liability for policy and contract claims. These estimates are based on historical claim payment patterns and expected loss ratios to provide for the inherent variability in claim patterns and severity. For the year ended December 31, 2009, the change in prior year incurred claims was primarily due to higher than expected paid claims for individual life offset by favorable changes in liability estimates for group medical stop-loss claims. For the year ended December 31, 2008, the change in prior year incurred claims was primarily due to higher than expected paid claims and unfavorable changes in liability estimates, primarily for group medical stop-loss claims. For the year ended December 31, 2007, the change in prior year incurred claims was primarily due to favorable changes in liability estimates related to group medical stop-loss claims. This was partially offset by higher-than-expected claims experience related to individual life insurance.

45

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

9. Capital and Surplus and Shareholder Dividends Restrictions

Under insurance regulations of the state of Washington, the Company is required to maintain minimum capital of at least $2,400,000 and additional unassigned funds of $2,400,000. Life and health insurance companies are also subject to certain RBC requirements as specified by the NAIC. Under those requirements, the amount of capital and surplus maintained by a life and health insurance company is to be determined based on various risk factors related to it. As of December 31, 2009, the Company met the minimum capital and surplus and RBC requirements.

There was an increase in special surplus funds of $38,662,583 due to implementation of SSAP No. 10R as of December 31, 2009. Please see Note 10 – Income Taxes, for more information.

The Company is restricted as to the amount of dividends that can be paid to its shareholder without prior approval of the Department. This restriction is the greater of statutory net gain from operations for the previous year or 10% of total capital and surplus at the close of the previous year, subject to a maximum limit equal to statutory unassigned funds. Based on this restriction, the maximum dividend payout that may be made without prior approval in 2010 is $141,543,511.

During 2009, the Company paid no dividends to its Parent.

During 2008, the Company paid dividends to its Parent, of $100,000,000 as follows:

Payment date	Ordinary		Extraordinary
March 27, 2008	$	—	$	40,000,000
June 23, 2008		—		30,000,000
September 19, 2008		—		30,000,000
Total	$	—	$	100,000,000

46

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

9. Capital and Surplus and Shareholder Dividends Restrictions (continued)

During 2007, the Company paid dividends to its Parent, of $166,400,000 as follows:

Payment date	Ordinary		Extraordinary
March 30, 2007	$	23,000,000	$	—
September 4, 2007		20,900,000		—
September 26, 2007		22,500,000		—
October 31, 2007		—		60,000,000
November 29, 2007		—		40,000,000
Total	$	66,400,000	$	100,000,000

The Company provided the required notification for all dividend payments and obtained approval from the Department prior to all extraordinary dividend payments.

On January 29, 2010, the Company received a cash capital contribution from its Parent of $210,700,000 from the net IPO proceeds.

The following table shows portion of unassigned funds (surplus) reduced by the following items:

	December 31,
	2009		2008
Unrealized losses	$	27,340,787	$	82,879,164
Nonadmitted assets		75,323,498		128,483,550
Asset valuation reserves		119,046,100		112,732,854
Provision for reinsurance		—		46,632

47

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

10. Income Taxes

The components of the net DTAs are as follows:

	December 31
	2009			2008
Gross DTAs – ordinary	$	115,556,126		$	133,800,503
Gross DTAs – capital		46,636,754			34,964,142
Total gross DTAs		162,192,880			168,764,645
Statutory valuation allowance – ordinary		—			—
Statutory valuation allowance – capital		—			—
Adjusted gross DTAs		162,192,880			168,764,645
Gross deferred tax liabilities – ordinary		(46,374,814	)		(42,134,045	)
Gross deferred tax liabilities – capital		—			—
Net DTAs		115,818,066			126,630,600
DTAs nonadmitted – ordinary		(16,010,411	)		(59,194,489	)
DTAs nonadmitted – capital		(18,724,016	)		(24,632,983	)
Total DTAs nonadmitted		(34,734,427	)		(83,827,472	)
Net admitted DTAs	$	81,083,639		$	42,803,128
(Increase) decrease in DTAs nonadmitted	$	49,093,045		$	(43,924,032	)

As described in Note 1, the Company has elected to admit an increased amount of DTAs pursuant to SSAP No. 10R, which increased its admitted DTAs by $38,662,583. This increase in admitted DTAs also increases admitted assets, statutory surplus, and total adjusted capital by the same amount.

The Company’s total adjusted capital and authorized control level before the additional amount admitted under SSAP No. 10R was $1,497,202,352 and $183,748,589, respectively, for the year ended December 31, 2009.

The Company has no deferred tax liabilities (DTL) which have not been recognized.

48

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

10. Income Taxes (continued)

The 2009 increase in admitted DTAs is summarized by tax character as follows:

	Ordinary		Capital		Total
Admitted through potential carry back – paragraph 10.a	$	23,492,884	$	18,928,172	$	42,421,056
Admitted through future realization – paragraph 10.b.i.		—		—		—
Admitted through offset of DTL – paragraph 10.c		46,374,814		—		46,374,814
Total admitted using one year reversal of DTAs		69,867,698		18,928,172		88,795,870
Admitted through potential carry back – paragraph 10.e.i.		48,552,916		32,530,723		81,083,639
Admitted through future realization – paragraph 10.e.ii.a.		—		—		—
Admitted through offset of DTL – paragraph 10.e.iii.		46,374,814		—		46,374,814
Total admitted using three year reversal of DTAs		94,927,730		32,530,723		127,458,453
Additional amount admitted under SSAP No. 10R	$	25,060,032	$	13,602,551	$	38,662,583

49

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

10. Income Taxes (continued)

The components of income tax expense are as follows:

	Year Ended December 31,
	2009			2008			2007
Current income taxes:
Current year tax provision	$	45,151,211		$	26,755,215		$	46,281,146
Tax credits		(9,570,102	)		(8,521,307	)		(4,641,517	)
Additional provided		—			(321,621	)		20,044
Prior year over accrual		(4,839,267	)		(2,963,089	)		(11,917,155	)
Income tax expense from operations		30,741,842			14,949,198			29,742,518
Taxes on capital gains (losses)		(21,327,802	)		8,326,263			33,141,636
Current income taxes incurred	$	9,414,040		$	23,275,461		$	62,884,154
The main components of deferred tax amounts are as follows:
	December 31,
	2009			2008			Net Change
Assets
Fixed assets/intangibles	$	8,603,126		$	8,908,189		$	(305,063	)
Investments		47,149,415			39,508,692			7,640,723
Nonadmitted assets		8,842,485			8,312,865			529,620
Proxy deferred acquisition costs		46,406,386			43,760,771			2,645,615
Reserves		37,870,713			35,429,926			2,440,787
Benefit accruals		1,247,645			1,194,475			53,170
Unrealized capital losses		10,707,956			30,637,914			(19,929,958	)
All others		1,365,154			1,011,813			353,341
Gross DTAs		162,192,880			168,764,645			(6,571,765	)
Liabilities
Investments		21,247,291			14,202,359			7,044,932
Deferred premium/loading		16,478,202			17,436,813			(958,611	)
Reserves		7,509,493			9,049,321			(1,539,828	)
All others		1,139,828			1,445,552			(305,724	)
Total DTLs	$	46,374,814		$	42,134,045		$	4,240,769

50

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

10. Income Taxes (continued)

	December 31,
	2009	2008	Net Change
Decrease in net DTA			$	(10,812,534	)
Surplus/other adjustments:
Tax effect of change in unrealized capital gains				19,929,958
Tax effect of change in nonadmitted assets				(529,620	)
Change in reserve method				175,920
Adjustments to prior year net DTAs				5,308,014
Change in net deferred income taxes			$	14,071,738

No adjustments were made to the Company’s gross DTAs because of a change in circumstances. The Company expects it will fully realize the DTAs and no statutory valuation allowance has been recorded as of December 31, 2009.

51

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

10. Income Taxes (continued)

Differences between the federal income tax provision and the change in deferred taxes computed by applying the United States federal income tax rate of 35% to the gain from operations before federal income taxes and the net realized capital losses and the actual tax provision are as follows:

	Year Ended December 31,
	2009			2008			2007
Significant statutory-to-tax adjustments on current taxes:
Ordinary income tax at federal statutory rate (35%)	$	56,073,039		$	39,959,296		$	57,735,388
Taxes on capital gains (losses) at federal statutory rate (35%)		(37,963,241	)		(12,482,636	)		28,612,724
Total income tax		18,109,798			27,476,660			86,348,112
Dividend-received deduction		(1,470,000	)		(1,365,000	)		(1,465,542	)
Tax-exempt income		(129,500	)		(133,000	)		(133,000	)
Tax credits		(9,570,102	)		(8,521,307	)		(4,641,517	)
Permanent items and other adjustments		181,013			224,415			201,988
Change in interest maintenance reserve		(6,939,639	)		(7,026,704	)		(6,885,184	)
Prior year over accrual		(4,839,268	)		(2,963,089	)		(11,917,155	)
Additional provided and other adjustments		—			(320,189	)		22,071
Federal income tax (benefit) expense	$	(4,657,698	)	$	7,371,786		$	61,529,773
Federal and foreign taxes incurred	$	9,414,040		$	23,275,461		$	62,884,154
Change in net deferred income taxes		(14,071,738	)		(15,903,675	)		(1,354,381	)
Total statutory income tax (benefit) expense	$	(4,657,698	)	$	7,371,786		$	61,529,773

52

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

10. Income Taxes (continued)

The Company files a life insurance consolidated federal income tax return with its subsidiaries. As a result, any loss carryforwards are calculated on a consolidated basis. As of December 31, 2009, the consolidated return had no loss carryforwards estimated. Tax capital losses incurred during 2009 will be fully absorbed through a carryback of the losses to offset capital gains generated in 2006.

The amount of federal income taxes incurred that are available for recovery in the event of the carryback of future net losses is as follows:

	Year Ended December 31,
	2009		2008		2007
Ordinary income	$	35,581,111	$	11,977,589	$	40,535,756
Capital gain		—		10,714,470		33,123,437

The Company’s federal income tax returns have been examined and closing agreements have been executed with the Internal Revenue Service or the statute of limitations has expired for all tax periods through December 31, 2003. The Internal Revenue Service is in the process of auditing the Company’s returns for the tax year ended July 31, 2004, filed in consolidation with the Company’s former parent, Safeco Corporation. To date, no significant tax issues or proposed adjustments have been raised by the examiners. The Internal Revenue Service has also completed an audit of the Company’s returns and the statute of limitations has closed for the years ended December 31, 2004 and 2005.

11. Employee Benefit Plans

The Company sponsors a defined contribution plan for all eligible employees. The Symetra Financial Retirement Plan is a 401(k) retirement plan that includes a matching contribution of 100% of a participant’s contributions, up to 6% of eligible compensation. Defined contribution plan expense was $3,811,673, $4,093,215, and $3,876,900 for the years ended December 31, 2009, 2008, and 2007, respectively.

The Company also participates in the Parent’s performance share plan (the Performance Share Plan), that provides incentives to selected executives based on the long-term success of the Company. Awards under the Performance Share Plan are typically made in the form of performance shares with a three-year award period. The value of each performance share is

53

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

11. Employee Benefit Plans (continued)

determined at the discretion of the Parent’s Board of Directors, based on achievement of a growth target, and is paid in cash. The expense recorded for grants related to the Performance Share Plan was $8,290,668, $5,977,901, and $9,384,372 for the years ended December 31, 2009, 2008, and 2007, respectively.

12. Separate Accounts

Funds received from sales of individual and group variable annuities, and variable life products are held in separate variable accounts. The assets of these accounts are held at fair value. Funds received from BOLI are held in separate fixed accounts, and the assets of these accounts are held at amortized cost.

Information regarding the separate accounts of the Company for the year ended December 31, 2009, is as follows:

	Nonindexed Guaranteed More Than/ Equal to 4%		Nonguaranteed Separate Accounts		Total
Premiums and other deposit funds	$	25,043,012	$	94,687,762	$	119,730,774
Reserves as of December 31, 2009:
For accounts with assets at:
Fair value	$	—	$	833,303,063	$	833,303,063
Amortized cost		3,192,144,811		—		3,192,144,811
Total	$	3,192,144,811	$	833,303,063	$	4,025,447,874
By withdrawal characteristics:
At fair value	$	—	$	833,303,063	$	833,303,063
At book value without fair value adjustment and with current surrender charge less than 5%		3,192,144,811		—		3,192,144,811
Total	$	3,192,144,811	$	833,303,063		4,025,447,874
Transfers from separate accounts						6,792,261
Payable for securities						66,270,849
Payable to general account						22,935,925
Total separate account liabilities					$	4,121,446,909

54

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

12. Separate Accounts (continued)

Information regarding the separate accounts of the Company for the year ended December 31, 2008, is as follows:

	Nonindexed Guaranteed More Than/ Equal to 4%		Nonguaranteed Separate Accounts		Total
Premiums and other deposit funds	$	28,875,508	$	128,614,688	$	157,490,196
Reserves as of December 31, 2008:
For accounts with assets at:
Fair value	$	—	$	709,174,770	$	709,174,770
Amortized cost		2,994,583,958		—		2,994,583,958
Total	$	2,994,583,958	$	709,174,770	$	3,703,758,728
By withdrawal characteristics:
At fair value	$	—	$	709,174,770	$	709,174,770
At book value without fair value adjustment and with current surrender charge less than 5%		2,994,583,958		—		2,994,583,958
Total	$	2,994,583,958	$	709,174,770		3,703,758,728
Transfers from separate accounts						6,913,278
Payable for securities						6,510,807
Payable to general account						4,327,075
Total separate account liabilities					$	3,721,509,888

Information regarding the Separate Accounts of the Company for the year ended December 31, 2007, is as follows:

	Nonindexed Guaranteed More Than/ Equal to 4%		Nonguaranteed Separate Accounts		Total
Premiums and other deposit funds	$	46,000,000	$	140,353,433	$	186,353,433

55

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

12. Separate Accounts (continued)

A reconciliation of the amounts transferred to and from the separate accounts is as follows:

	Year Ended December 31,
	2009			2008			2007
Transfers as reported in statements of income of the Separate accounts’ Annual Statements:
Transfers to separate accounts	$	257,168,185		$	296,525,116		$	306,967,149
Transfers from separate accounts		(238,623,063	)		(286,012,172	)		(206,558,369	)
Net transfers as reported in the statements of income	$	18,545,122		$	10,512,944		$	100,408,780

13. Related-Party Transactions

The following transactions were entered into by the Company with affiliates. Non-insurance transactions involving less than 0.5% of the total assets of the Company are omitted, with the exception of cost allocation transactions, which are discussed separately.

On December 7, 2009 and December 2, 2008, the Company contributed $20,000,000 in cash to First Symetra National Life Insurance Company of New York, its subsidiary.

On May 5, 2009 and December 31, 2009, the Company received noncash contributions of bonds and fixed assets of $101,984,661 and $83,604, respectively, from its Parent.

On December 22, 2008, the Company received bonds and cash contributions of $49,729,250 and $270,750, respectively, from its Parent.

On December 24, 2009, the Company received a cash dividend of $1,000,000 from Symetra National Life Insurance Company, its subsidiary.

The Company is party to an Investment Management Agreement with White Mountains Advisors, LLC., a subsidiary of White Mountains Investments Group, Ltd., an affiliate of the Parent. This agreement provides for investment advisory services related to the Company’s invested assets and portfolio management services. Expenses amounted to $13,156,938, $13,611,647, and $14,395,128 for the years ended December 31, 2009, 2008, and 2007, respectively.

56

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

13. Related-Party Transactions (continued)

Symetra Assigned Benefits Service Company (SABSCO), an affiliate of the Company, purchased at a discount from third-party payees future payment streams from structured settlement annuity contracts assigned to and owned by SABSCO and issued by the Company. The payments to annuitants totaled $60,463,906, $53,140,331, and $40,352,079 during the years ended December 31, 2009, 2008, and 2007, respectively. The Company, in turn, issued commutation endorsements to SABSCO to commute the payment streams in the structured settlement annuity contracts. During the years ended December 31, 2009, 2008, and 2007, the Company paid $59,737,590, $43,121,598, and $49,974,679, respectively, to SABSCO related to the commutation endorsements.

The Company paid concessions, general agent fees, administrative and underwriting fees to its affiliates, Symetra Investment Services, Inc., Symetra Securities, Inc., Medical Risk Managers, Inc., and Symetra Administrative Services, Inc. totaling $9,489,651, $9,728,329, and $10,306,841 for the years ended December 31, 2009, 2008, and 2007, respectively. These payments are included in general insurance expenses in the statements of income.

The Company has not agreed to any guarantees for affiliates.

The Company has a Services and Shared Expenses Agreement with its affiliates under common ownership with the Parent, whereby the parties each agree to provide and receive from each other certain general services (related to sharing common management, personnel, and facilities) and to share the expense thereof. Total related-party rent expense for all facilities charged to operations was $5,808,506, $5,805,056, and $5,844,528 for the years ended December 31, 2009, 2008, and 2007, respectively. Other operating expenses and intercompany cost allocations, including the Performance Share Plan due from and to the Parent, subsidiaries, and affiliates was a net receivable of $2,086,688 as of December 31, 2009 and a net payable of $14,124,631 as of December 31, 2008.

14. Commitments and Contingencies

Guaranty Fund Assessments

Under state insolvency and guaranty laws, insurers licensed to do business in the state can be assessed or required to contribute to state guaranty funds to cover policyholder losses resulting from insurer insolvencies. Liabilities for guaranty funds are not discounted or recorded net of

57

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

14. Commitments and Contingencies (continued)

premium taxes and are included in other liabilities in the balance sheets. As of December 31, 2009 and 2008, the Company had liabilities of $11,474,726 and $7,272,338, respectively, for estimated guaranty fund assessments. The Company had a related asset for premium tax offsets of $7,983,460 and $5,791,158 as of December 31, 2009 and 2008, respectively, which is available for a period of five to 20 years.

Investment in Limited Partnerships

As of December 31, 2009, the Company was invested in seven limited partnership interests related to federal affordable housing projects and five state tax credit funds, two of which were entered into during 2009. The Company unconditionally committed to provide capital contributions of approximately $117,098,543 over a period of three years. Capital contributions of $78,182,460 were paid as of December 31, 2009. The investments are carried at amortized cost with the present value of the unfunded contributions of $35,064,439 recorded in other liabilities. The expected capital contributions are payable as follows:

	Expected Capital Contributions
2010	$	32,519,213
2011		1,351,693
2012		1,193,533
Total capital contributions payable	$	35,064,439

Litigation

Because of the nature of the business, the Company is subject to legal actions filed or threatened in the ordinary course of its business operations. The Company does not expect that any such litigation, pending or threatened as of December 31, 2009, will have a material adverse effect on its financial condition, future operating results, or liquidity.

58

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

14. Commitments and Contingencies (continued)

Leases

The Company leases office space, commercial real estate, and certain equipment under leases that expire at various dates through 2015. The Company accounts for these leases as operating leases. Certain leases include renewal options. The minimum lease commitments, including cost escalation clauses, for the next five years and thereafter are as follows:

	Minimum Rentals
2010	$	1,310,190
2011		815,804
2012		612,952
2013		333,682
2014 and thereafter		216,515
Total lease commitments	$	3,289,143

The amount of rent expense incurred was $6,647,252, $7,712,767, and $6,400,836 for the years ended December 31, 2009, 2008, and 2007, respectively. Rent expense primarily relates to rent paid to the Parent for office space.

Other Commitments

On August 1, 2009, the Company entered into a new service agreement with a third-party service provider to outsource the majority of its information technology infrastructure, effectively terminating the previous agreement with this vender which was scheduled to expire in July 2010. The initial term of the new service agreement expires in July 2014, subject to early termination in certain cases, with two one-year extensions at the Company’s election. Under the terms of the service agreement, the Company agreed to pay an annual service fee ranging from $10,579,644 to $11,414,520 for five years. The Company incurred service fee expenses of $11,217,576, $11,810,846, and $12,831,562 for the years ended December 31, 2009, 2008, and 2007, respectively.

As of December 31, 2009, 2008, and 2007, unfunded mortgage loan commitments were $4,010,000, $9,000,000, and $1,500,000, respectively.

The Company had no other material commitments or contingencies as of December 31, 2009 and 2008.

59

Symetra Life Insurance Company

Notes to Financial Statements – Statutory Basis (continued)

15. Organization Chart

The following table represents the Company’s organizational chart as of December 31, 2009.

Name	FEIN	NAIC #	Domicile	Ownership
Symetra Financial Corporation	20-0978027		DE	26.3	% **	White Mountains Insurance Group, Ltd.*
				26.3	% **	Berkshire Hathaway, Inc.
				11.7	%	Franklin Mutual Advisors, LLC
				35.7	%	Other equity investors (each with less than 10% ownership)
Symetra Life Insurance Company	91-0742147	68608	WA	100.0	%	Symetra Financial Corporation
Symetra National Life Insurance Company	91-1079693	90581	WA	100.0	%	Symetra Life Insurance Company
First Symetra National Life Insurance Company of New York	91-1367496	78417	NY	100.0	%	Symetra Life Insurance Company
Symetra Assigned Benefits Service Company	91-1246870		WA	100.0	%	Symetra Financial Corporation
Symetra Administrative Services, Inc.	91-1364981		WA	100.0	%	Symetra Financial Corporation
Symetra Securities, Inc.	91-0824835		WA	100.0	%	Symetra Financial Corporation
Symetra Services Corporation	91-0887019		WA	100.0	%	Symetra Financial Corporation
Symetra Investment Services, Inc.	91-1354455		WA	100.0	%	Symetra Financial Corporation
TFS Training & Consulting, Inc.	20-3494693		WA	100.0	%	Symetra Financial Corporation
Clearscape Funding Corporation	20-3820455		WA	100.0	%	Symetra Financial Corporation
WSF Receivable I, LLC	26-1099574		FL	100.0	%	Clearscape Funding Corporation
Health Network Strategies, LLC	20-8947838		DE	60.0	%	Symetra Financial Corporation
				40.0	%	Other members
Medical Risk Managers, Inc.	51-0309072		DE	100.0	%	Symetra Financial Corporation
TIF Invest III, LLC	26-3530060		DE	100.0	%	Symetra Financial Corporation

As of January 27, 2010, White Mountains Insurance Group, Ltd. and Berkshire Hathaway, LLC each beneficially own 21.8%, including the warrants, and Franklin Mutual Advisors, LLC beneficially owns 9.5%. The remaining equity investors, each with less than 10% ownership, own 46.9%

* Controlling entity

**  Includes warrants exercisable for common shares

60

Report of Independent Registered Public Accounting Firm

The Board of Directors

Symetra Life Insurance Company

We have audited the statutory-basis financial statements of Symetra Life Insurance Company (the Company) as of December 31, 2009 and 2008, and for each of the three years in the period ended December 31, 2009, and have issued our report thereon dated April 16, 2010 (included elsewhere in this Registration Statement). Our audits also included the following financial statement schedules: Schedule I – Summary of Investments – Other Than Investments in Related Parties; Schedule IV – Reinsurance; and Schedule VI – Supplemental Information Concerning Insurance Operations. These schedules are the responsibility of the Company’s management. Our responsibility is to express an opinion based on our audits.

In our opinion, the financial statement schedules referred to above, when considered in relation to the financial statements taken as a whole, present fairly in all material respects the information set forth therein.

/s/ Ernst & Young LLP

Seattle, Washington

April 16, 2010

61

Symetra Life Insurance Company

Schedule I

Summary of Investments-Other Than Investments in Related Parties

	Year Ended December 31, 2009
Bonds:	Cost		Fair Value		Amount as Shown in the Balance Sheet
U.S. government and agencies	$	23,549,464	$	27,116,410	$	24,551,768
Foreign governments and agencies		17,499,908		20,002,423		17,422,769
States, territories, and possessions		5,410,000		5,450,708		5,410,000
Political subdivisions		145,810,266		230,855,418		234,181,376
Special revenue and assessments		178,213,516		236,616,547		241,943,917
Industrial and miscellaneous		9,798,161,665		10,108,013,049		9,680,672,649
Hybrid securities		547,269,303		458,201,291		547,488,553
Mortgage-backed/asset-backed securities		3,718,870,781		3,724,569,042		3,728,439,990
Total bonds		14,434,784,903		14,810,824,888		14,480,111,022
Preferred stocks:
Industrial and miscellaneous		63,797,485		50,220,747		63,178,945
Total preferred stocks		63,797,485		50,220,747		63,178,945
Common stocks:
Nonaffiliated		138,028,239		149,905,772		149,905,772
Total common stocks1		138,028,239		149,905,772		149,905,772
Other invested assets
Limited partnership and other invested assets		113,469,246		84,552,891		84,552,891
Surplus Notes		35,196,038		31,620,364		34,988,317
Total other invested assets		148,665,284		116,173,255		119,541,208
Total Invested Assets	$	14,785,275,911	$	15,127,124,662	$	14,812,736,947

¹ The amount shown in the Balance Sheet for common stocks differs from cost and fair value, as these investments include affiliated common stocks with a cost and fair value of $73,405,552 and $76,998,356, respectively.

	Year Ended December 31, 2008
Bonds:	Cost		Fair Value		Amount as Shown in the Balance Sheet
U.S. government and agencies	$	62,671,274	$	83,439,930	$	80,470,561
Foreign governments and agencies		11,805,662		12,831,009		11,834,156
States, territories, and possessions		13,352,180		16,939,169		13,317,707
Political subdivisions		150,320,602		205,911,346		228,725,235
Special revenue and assessments		180,626,490		234,322,393		240,015,546
Industrial and miscellaneous		8,313,782,682		7,497,494,581		8,209,325,543
Mortgage-backed/asset-backed securities		3,529,562,799		3,332,413,524		3,530,101,307
Total bonds		12,262,121,689		11,383,351,952		12,313,790,055
Preferred stocks:
Hybrid securities		517,287,891		372,767,662		497,050,594
Industrial and miscellaneous		63,582,217		48,312,630		63,008,044
Total preferred stocks		580,870,108		421,080,292		560,058,638
Common stocks:
Nonaffiliated		151,781,801		103,709,066		103,709,066
Total common stocks2		151,781,801		103,709,066		103,709,066
Other invested assets
Limited partnership and other invested assets		101,359,901		82,412,576		82,412,574
Surplus Notes		35,196,038		31,368,186		35,013,365
Total other invested assets		136,555,939		113,780,762		117,425,939
Total Invested Assets	$	13,131,329,537	$	12,021,922,072	$	13,094,983,698

² The amount shown in the Balance Sheet for common stocks differs from cost and fair value, as these investments include affiliated common stocks with a cost and fair value of $51,888,098 and $56,784,961, respectively.

62

Symetra Life Insurance Company

Schedule IV – Reinsurance

	Gross amount	Ceded to other companies	Assumed from companies	Net amount	Percentage  of amount assumed to net
For the year ended December 31, 2009
Life insurance in-force	54,915,670,706	24,216,464,412	199,870,405	30,699,206,294	0.7	%
For the year ended December 31, 2008
Life insurance in-force	55,702,179,479	24,161,728,197	223,124,966	31,540,451,282	0.7	%
For the year ended December 31, 2007
Life insurance in-force	56,382,419,705	23,778,862,022	215,266,365	32,603,557,683	0.7	%

63

Symetra Life Insurance Company

Schedule VI – Supplemental Information Concerning Insurance Operations

Segment	Policy and  contract liabilities (1)		Unearned premiums		Liability for deposit type contracts		Premium and annuity considerations		Net investment income		Benefits			General insurance expenses
Year ended December 31, 2009
Group	$	113,185,803	$	1,708,884	$	1,107,125	$	421,800,497	$	17,201,137	$	286,746,551		$	73,785,962
Retirement Services		6,900,052,551		—		117,728,381		2,121,284,096		365,786,280		2,380,651,117			60,800,215
Income Annuities		3,840,754,017		—		2,189,741,048		150,777,785		445,915,461		545,547,914			17,106,184
Individual		1,529,037,985		381,585		312,302		134,065,178		98,824,651		105,490,809			47,942,841
Other		—		—		—		—		19,781,638		6,011			1,805,365
	$	12,383,030,356	$	2,090,469	$	2,308,888,856	$	2,827,927,556	$	947,509,167	$	3,318,442,402		$	201,440,567
Year ended December 31, 2008
Group	$	129,016,107	$	954,056	$	1,330,423	$	441,438,997	$	17,225,769	$	291,636,110		$	75,084,265
Retirement Services		5,189,638,798		—		119,467,182		1,627,527,379		252,965,206		1,844,451,439			62,140,917
Income Annuities		3,759,558,469		—		2,298,179,830		74,292,237		446,201,210		495,518,014			18,902,790
Individual		1,632,001,352		486,257		304,285		131,886,419		98,229,812		113,447,812			47,749,812
Other		—		—		—		—		28,243,959		68			489,799
	$	10,710,214,726	$	1,440,313	$	2,419,281,720	$	2,275,145,032	$	842,865,956	$	2,745,053,443		$	204,367,583
Year ended December 31, 2007
Group	$	107,481,120	$	1,315,701	$	1,536,439	$	385,987,648	$	17,675,178	$	209,573,679		$	75,825,814
Retirement Services		4,128,008,881		—		141,616,138		693,243,491		244,413,106		968,903,211			61,883,173
Income Annuities		3,725,388,916		—		2,422,153,837		47,747,539		458,445,561		475,504,841			19,611,276
Individual		1,643,396,241		377,493		312,981		154,106,027		102,437,861		9,805,675			48,628,924
Other		—		—		—		—		32,807,360		(138	)		4,021,873
	$	9,604,275,158	$	1,693,194	$	2,565,619,395	$	1,281,084,705	$	855,779,066	$	1,663,787,268		$	209,971,060

(1) This includes life and annuity reserves, accident and health reserves, and policy and contract claims.

64

SYMETRA SEPARATE ACCOUNT C

PART C

OTHER INFORMATION

Item 24. Financial Statements and Exhibits

a. Financial Statements The following audited financial statements of Symetra Separate Account C and Symetra Life Insurance Company (“Symetra Life”) are included in the Statement of Additional Information of this Registration Statement:

1. The financial statements of Symetra Separate Account C as of December 31, 2009 and for each of the two years in the period then ended.

2. The statutory-basis financial statements of Symetra Life Insurance Company as of December 31, 2009 and 2008, and for each of the three years in the period ended December 31, 2009.

3. Financial Statement Schedules for Symetra Life Insurance Company.

• Schedule I – Summary of Investments – Other Than Investments in Related Parties

• Schedule IV – Reinsurance

• Schedule VI – Supplemental Information Concerning Insurance Operations

We omit other schedules from this list – and from this Registration Statement – because they either are not applicable for the information is included in our audited financial statements.

b. Exhibits

Exhibit	Description	Reference
1.	Resolution of Board of Directors of Symetra Life authorizing the Separate Account	1/
2.	Not Applicable
3.	(a)       Principal Underwriter’s Agreement            Amendment to Principal Underwriter’s Agreement (b)      Broker-Dealer Selling Agreement	1/ 4/ 2/
4.	(a)       Form of Individual Flexible Premium Deferred Variable Annuity Contract (b)      Form of Individual Flexible Premium Deferred Variable Annuity 457 Contract (c)       Form of Individual Flexible Premium Deferred Variable Annuity Contract Data Page (d)      Form of Individual Flexible Premium Deferred Variable Annuity 457 Contract Data Page (e)       Form of Guaranteed Minimum Death Benefit – Age Extension (f)       Form of Guaranteed Minimum Death Benefit – Age Extension for 457 Contract (g)      Form of Capital Preservation Rider (“CPR”) (h)      Form of Non-Qualified Guaranteed Long Life Benefit Rider (i)       Form of Qualified Guaranteed Long Life Benefit Rider (j)       Form of TSA Endorsement (No Loan)	11/ 13/ 13/ 13/ 5/ 13/ 11/ 13/ 13/ 15/
5.	Form of Application for Annuity Contract	Filed Herewith
6.	(a)       Copy of Articles of Incorporation of Symetra Life as amended11/26/90.            Amendment to Articles of Incorporation of Symetra Life dated 9/1/04            Amendment to Articles of Incorporation of Symetra Life dated 5/27/05 (b)      Copy of the Bylaws of Symetra Life as last amended 12/6/05	1/ 3/ 12/ 12/
7.	Not Applicable
8.	Participation Agreement (Fidelity)	6/
	Sub-Licensing Agreement Amendment No. 1 to Participation Agreement (Fidelity)	6/ 9/
	Amendment No. 2 to Participation Agreement (Fidelity)	14/

Exhibit	Description	Reference
	Participation Agreement (Vanguard)         Amendment No. 1 to Participation Agreement (Vanguard)	7/ 8/
	Participation Agreement (Ibbotson)	7/
	Amendment No. 1 to Participation Agreement (Ibbotson)	10/
	Participation Agreement (DWS/Scudder)	10/
	Amendment No. 1 to Participation Agreement (DWS)	14/
9.	Opinion and Consent of Counsel	12/
10.	Consent of Ernst and Young LLP, Independent Registered Public Accounting Firm	Filed Herewith
11.	Not Applicable
12.	Not Applicable

1/ Incorporated by reference to Registrant’s Initial Product Filing to Form N-4 registration statement of Symetra Separate Account C filed with the Securities and Exchange Commission (“SEC”) on June 16, 1995 (File No. 33-60331).

2/ Incorporated by reference to Registrant’s Post-Effective Amendment No. 22 on Form N-6 registration statement of Symetra Separate Account SL filed with the SEC on December 19, 2002 (File No. 333-30329).

3/ Incorporated by reference to Registrant’s Post-Effective Amendment No. 17 on Form N-4 registration statement of Symetra Separate Account C filed with the SEC on December 3, 2004 (File No. 33-69712).

4/ Incorporated by reference to Registrant’s Post-Effective Amendment No. 23 on Form N-4 registration statement of Symetra Separate Account C filed with the SEC on April 28, 2006 (File No. 33-69712).

5/ Incorporated by reference to Registrant’s Initial Product Filing to Form N-4 registration statement of Symetra Separate Account C filed with the SEC on September 18, 2006 (File No. 333-137411).

6/ Incorporated by reference to Registrant’s Post-Effective Amendment No. 34 on Form N-6 registration statement of Symetra Separate Account SL filed with the SEC on April 30, 2007 (File No. 333-30329).

7/ Incorporated by reference to Registrant’s Pre-Effective Amendment No. 1 on Form N-4 registration statement of Symetra Separate Account C filed with the SEC on May 15, 2007 (File No. 333-137411).

8. Incorporated by reference to Registrant’s Post-Effective Amendment No. 2 on Form N-6 registration statement of Symetra Separate Account SL filed with the SEC on August 15, 2007 (File No. 333-136776).

9/ Incorporated by reference to Registrant’s Post-Effective Amendment No. 1 on Form N-4 registration statement of Symetra Separate Account C filed with the SEC on January 31, 2008 (File No. 333-137411).

10/ Incorporated by reference to Registrant’s Post-Effective Amendment No. 25 on Form N-4 registration statement of Symetra Separate Account C filed with the SEC on April 30, 2008 (File No. 33-69712).

11/	Incorporated by reference to Registrant’s Post-Effective Amendment No. 5 on Form N-4 registration statement of Symetra Separate Account C filed with the SEC on May 29, 2008 (File No. 333-137411).
12/	Incorporated by reference to Registrant’s Post-Effective Amendment No. 8 on Form N-4 registration statement of Symetra Separate Account C filed with the SEC on August 28, 2008 (File No. 333-137411).
13/	Incorporated by reference to Registrant’s Post-Effective Amendment No. 9 on Form N-4 registration statement of Symetra Separate Account C filed with the SEC on April 30, 2009 (File No. 333-137411).
14/	Incorporated by reference to Registrant’s Pre-Effective Amendment No. 1 on Form N-4 registration statement of Symetra Separate Account C filed with the SEC on December 3, 2009 (File No. 333-158141).
15/	Incorporated by reference to Registrant’s Post-Effective Amendment No. 27 to Form N-4 registration statement of Symetra Separate Account C filed with the SEC on April 29, 2010 (File No. 33-69712).

Item 25. Directors and Officers of the Depositor

Set forth below is a list of each director and officer of Symetra Life who is engaged in activities relating to Symetra Separate Account C or the variable annuity contracts offered through Symetra Separate Account C.

Name	Positions with Symetra	Principal Business Address
Randall H. Talbot	Director and President	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Allyn D. Close	Director and Senior Vice President	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
George C. Pagos	Director, Senior Vice President, General Counsel and Secretary	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Jennifer V. Davies	Director and Senior Vice President	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Margaret A. Meister	Director, Chief Financial Officer and Executive Vice President	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Tommie D. Brooks	Vice President and Chief Actuary	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Colleen M. Murphy	Vice President, Controller, Treasurer and Assistant Secretary	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Jean B. Liebmann	Assistant Vice President and Actuary	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Michele M. Kemper	Vice President and Chief Compliance Officer of the Separate Account	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Linda C. Mahaffey	Vice President	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Michael W. Fry	Director and Senior Vice President	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Richard J. Lindsay	Director and Senior Vice President	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Patrick B. McCormick	Senior Vice President	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004

Item 26. Persons Controlled By or Under Common Control With the Depositor or Registrant

No person is directly or indirectly controlled by Symetra Separate Account C (“Registrant”). Symetra Life established Registrant by resolution of its Board of Directors pursuant to Washington law. Symetra Life is a wholly owned subsidiary of Symetra Financial Corporation. Symetra Financial Corporation is organized under Delaware law and Symetra Life is organized under Washington law. All subsidiaries are included in consolidated financial statements. In addition, Symetra Life files a separate financial statement in connection with its issuance of products associated with the Registrant and other separate accounts. Following is the organizational chart of Symetra Financial Corporation.

Name	Ownership	State of Incorporation	Business
Symetra Financial Corporation	Holding Company	DE	Insurance Holding Company
Symetra Life Insurance Company	100% Symetra Financial Corporation	WA	Life Insurance Company
Symetra National Life Insurance Company	100% Symetra Life Insurance Company	WA	Life Insurance Company

First Symetra National Life Insurance Company of New York	100% Symetra Life Insurance Company	NY	Life Insurance Company
Symetra Assigned Benefits Service Company	100% Symetra Financial Corporation	WA	Structured Settlements
Symetra Administrative Services, Inc.	100% Symetra Financial Corporation	WA	Holding Company
Symetra Securities, Inc.	100% Symetra Financial Corporation	WA	Broker Dealer/ Underwriter
Symetra Services Corporation	100% Symetra Financial Corporation	WA	Administrative Services
Symetra Investment Services, Inc.	100% Symetra Financial Corporation	WA	Broker Dealer
TFS Training & Consulting, Inc.	100% Symetra Financial Corporation	WA	Training and Consulting
Clearscape Funding Corporation	100% Symetra Financial Corporation	WA	Structured Settlements Factoring
WSF Receivables I, LLC	100% Clearscape Funding Corporation	FL	Investment
Medical Risk Managers, Inc.	100% Symetra Financial Corporation	DE	Managing Underwriter
Health Network Strategies, LLC	60% Symetra Financial Corporation, 40% Other Members	DE	Benefit Plan Consultant
TIF Invest III, LLC	100% Symetra Financial Corporation	DE	Investment

Item 27. Number of Contract Owners

As of March 31, 2010, there were 24,165 Contract Owners under the Registrant.

Item 28. Indemnification

Under its Bylaws, Symetra Life, to the full extent permitted by the Washington Business Corporation Act, shall indemnify any person who was or is a party to any proceeding (whether brought by or in the right of Symetra Life or otherwise) by reason of the fact that he or she is or was a director of Symetra Life, or, while a director of Symetra Life, is or was serving at the request of Symetra Life as a director, officer, partner, trustee, employee, or agent of another foreign or domestic corporation, partnership, joint venture, trust, other enterprise, or employee benefit plan, against judgments, penalties, fines, settlements and reasonable expenses actually incurred by him or her in connection with such proceeding.

Symetra Life shall extend such indemnification as is provided to directors above to any person, not a director of Symetra Life, who is or was an officer of Symetra Life or is or was serving at the request of Symetra Life as a director, officer, partner, trustee, or agent of another foreign or domestic corporation, partnership, joint venture, trust, other enterprise, or employee benefit plan. In addition, the Board of Directors of Symetra Life may, by resolution, extend such further indemnification to an officer or such other person as it may seem fair and reasonable in view of all relevant circumstances.

Under certain Director and Officer Indemnification Agreements (“Agreement(s)”) between Symetra Life’s parent company, Symetra Financial Corporation, and directors and/or officers of Symetra Life (“Indemnitees”), Symetra Financial Corporation indemnifies and holds harmless Indemnitees, to the full extent permitted by the laws of the State of Delaware in effect at the time the Agreement is effective or as such laws may from time to time be amended, against all Indemnifiable Losses related to, resulting from or arising out of any Claim (subject to certain exceptions) where:

• a “Claim” means any threatened, pending or completed action, suit or proceeding, or any inquiry or investigation, whether instituted, made or conducted by Symetra Financial Corporation or any other party, including without limitation any governmental entity, that an Indemnitee determines might lead to the institution of any such action, suit or proceeding, whether civil, criminal, administrative, arbitrative, investigative or other;

• “Indemnifiable Losses” means any and all Expenses, damages, losses, liabilities, judgments, fines, penalties and amounts paid in settlement (including without limitation all interest, assessments and other charges paid or payable in connection with or in respect of any of the foregoing) (collectively “Losses”) relating to, resulting from or arising out of any Claims by reason of the fact that (i) Indemnitee is or was a director, officer, employee or agent of Symetra Financial Corporation and/or of a subsidiary of Symetra Financial Corporation; or (ii) Indemnitee is or was serving at the request of Symetra Financial Corporation as a director, officer, employee or agent of another corporation, partnership, non-profit organization, joint venture, trust or other enterprise; and

• “Expenses” includes against all direct and indirect costs and expenses of any type whatsoever (including without limitation all attorneys’ and experts’ fees, expenses and charges) and all other costs, expenses and obligations actually and reasonably paid or incurred in connection with investigating, defending, being a witness in or participating in (including on appeal), or preparing to investigate, defend, be a witness in or participate in, a claim.

Insofar as indemnification for liabilities arising under the Securities Act of 1933 may be permitted to directors, officers and controlling persons of Symetra Life pursuant to such provisions of the bylaws, statutes, agreements, or otherwise, Symetra Life has been advised that in the opinion of the Securities and Exchange Commission, such indemnification is against public policy as expressed in said Act and is, therefore, unenforceable. In the event that a claim for indemnification against such liabilities (other than the payment by Symetra Life or Symetra Financial Corporation of expenses incurred or paid by a director, officer or controlling person of Symetra Life in the successful defense of any such action, suit or proceeding) is asserted by such director, officer or controlling person in connection with the contracts issued by the Separate Account, Symetra Life 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 said Act and will be governed by the final adjudication of such issue.

Item 29. Principal Underwriters

a. Symetra Securities, Inc., the principal underwriter for the contracts, also acts as the principal underwriter for other Symetra Life individual variable annuity contracts, Symetra Life’s Group variable annuity contracts and Symetra Life’s Individual Flexible Premium Variable Life Insurance Policies.

b. The following information is provided for each officer and director of the principal underwriter:

Name	Positions and Offices with Underwriter	Principal Business Address
Linda C. Mahaffey	Director and President	777 108th Ave NE, Suite 1200 Bellevue, WA 98004
Margaret A. Meister	Director	777 108th Ave NE, Suite 1200 Bellevue, WA 98004
Joanne M. Salisbury	Vice President	777 108th Ave NE, Suite 1200 Bellevue, WA 98004
LeeAnna G.K. Glessing	Assistant Vice President, Treasurer and Financial Principal	777 108th Ave NE, Suite 1200 Bellevue, WA 98004
Allyn D. Close	Director	777 108th Ave NE, Suite 1200 Bellevue, WA 98004
Michael F. Murphy	Assistant Vice President and Chief Compliance Officer	777 108th Ave NE, Suite 1200 Bellevue, WA 98004
Laurie A. Hubbard	Vice President	777 108th Ave NE, Suite 1200 Bellevue, WA 98004

c. During the fiscal year ended December 31, 2009, Symetra Securities, Inc. received $3,719,093 in commissions for the distribution of certain annuity contracts sold in connection with Registrant of which no payments were retained. Symetra Securities, Inc. did not receive any other compensation in connection with the sale of Registrant’s contracts.

Item 30. Location of Accounts and Records

Symetra Life Insurance Company at 777 108^th Avenue NE, Suite 1200, Bellevue, Washington 98004 maintains physical possession of the accounts, books or documents of the Separate Account required to be maintained by Section 31(a) of the Investment Company Act of 1940 and the rules promulgated thereunder.

Item 31. Management Services

Not Applicable

Item 32. Undertakings

1. The Registrant hereby undertakes to:

a. File a post-effective amendment to this registration statement as frequently as is necessary to ensure that the audited financial statements in the registration statement are never more than 16 months old for so long as payments under the variable annuity contracts may be accepted;

b. Include either (1) as part of any application to purchase a contract offered by the prospectus, a space that an applicant can check to request a Statement of Additional Information, or (2) a post card or similar written communication affixed to or included in the prospectus that the applicant can remove to send for a Statement of Additional Information; and

c. Deliver any Statement of Additional Information and any financial statements required to be made available under this Form promptly upon written or oral request.

Representations

1. Registrant hereby represents that it is relying upon a No-Action Letter issued to the American Council of Life Insurance dated November 28, 1988 (Commission ref. IP-6-88) and that the following provisions have been complied with:

a. Include appropriate disclosure regarding the redemption restrictions imposed by Section 403(b)(11) in each registration statement, including the prospectus, used in connection with the offer of the contract;

b. Include appropriate disclosure regarding the redemption restrictions imposed by Section 403(b)(11) in any sales literature used in connection with the offer of the contract;

c. Instruct sales representatives who solicit participants to purchase the contract specifically to bring the redemption restrictions imposed by Section 403(b)(11) to the attention of the potential participants; and

d. Obtain from each plan participant who purchases a Section 403(b) annuity contract, prior to or at the time of such purchase, a signed statement acknowledging the participant’s understanding of (1) the restrictions on redemption imposed by Section 403(b)(11), and (2) other investment alternatives available under the employer’s Section 403(b) arrangement to which the participant may elect to transfer his contract value.

Item 33. Fee Representation

Pursuant to the Investment Company Act of 1940, Symetra Life represents that the fees and charges deducted under the contract, in the aggregate, are reasonable in relation to the services rendered, the expenses expected to be incurred and risks assumed by Symetra Life.

SIGNATURES

As required by the Securities Act of 1933 and the Investment Company Act of 1940, the Registrant certifies that it meets all of the requirements of Securities Act Rule 485(b) for effectiveness of this Registration Statement and has duly caused this Registration Statement to be signed on its behalf, in the City of Bellevue and State of Washington, on this 29^th day of April 2010.

	Symetra Separate Account C
	Registrant
By:	Symetra Life Insurance Company
By:	RANDALL H. TALBOT*
	Randall H. Talbot, President
	Symetra Life Insurance Company
	Depositor
By:	RANDALL H. TALBOT*
	Randall H. Talbot, President

Pursuant to the requirement of the Securities Act of 1933, this Registration Statement has been signed below by the following person in the capacities and on the dates indicated. Those signatures with an asterisk indicate that the signature was supplied by a duly appointed attorney-in-fact under a valid Power of Attorney which is incorporated by reference to Form N-4 registration statement of Symetra Separate Account C filed with the SEC on December 3, 2009 (File No. 333-158141).

NAME	TITLE
Allyn D. Close * Allyn D. Close	Director and Senior Vice President
Jennifer V. Davies * Jennifer V. Davies	Senior Vice President
Michael W. Fry * Michael W. Fry	Director and Senior Vice President
Richard J. Lindsay * Richard J. Lindsay	Director and Senior Vice President
Margaret A. Meister * Margaret A. Meister	Director, Chief Financial Operator and Executive Vice President
Colleen M. Murphy * Colleen M. Murphy	Vice President, Controller, Treasurer and Assistant Secretary
/s/ George C. Pagos George C. Pagos	Director, Senior Vice President, General Counsel and Secretary
Randall H. Talbot * Randall H. Talbot	Director and President