Combined Enhanced and Guaranteed Growth Death Benefit

Available during accumulation phase. Upon death of owner, benefit will be greatest of - 1) contract value plus enhanced death benefit, 2) total purchase payments adjusted for withdrawals, or 3) guaranteed growth death benefit at 5% plus enhanced death benefit. Guaranteed growth death benefit is equal to purchase payment accumulated at 5% annually, until earliest of - i) annuitization, ii) contract anniversary following annuitant's 80th birthday, iii) death, or iv) six-month anniversary of owner's death, thereafter increase by credit enhancements or bonus credits and adjusted for withdrawals. Enhanced death benefit is lesser of - 1) 50% (25% if age at issue is 70 or older) of contract gain, or 2) 25% (25% if age at issue 70 or older) of adjusted purchase payments. Contract gain equal to contract value less adjusted purchase payments. Please see prospectus for details.