Highest Daily Value Death Benefit

Available during accumulation phase. Upon death of owner or annuitant, benefit will be greatest of - 1) total purchase payments adjusted for withdrawal; 2) contract value; or 3) Highest Daily Value. Initially highest daily value is equal to purchase payment, thereafter on any valuation day, equal to greater of - 1) previous highest daily value; or 2) contract value on each valuation day prior to target date adjusted for withdrawals and subsequent payments made since that date. Target date is later of - 1) contract anniversary following owner's 80th birthday; or 2) 5th contract anniversary. Owner must participate in Asset Allocation Program and select one of asset allocation models.