Combination 5% Roll-Up and Highest Anniversary 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, 3) highest anniversary value, or 4) 5% roll-up. Highest anniversary value is equal to greater of - 1) total purchase payments adjusted for withdrawal; 2) contract value; 3) highest anniversary value as of annuitant or owner's date of death, but prior to target date, adjusted for withdrawals and subsequent payments made since that date. 5% Roll-up value is equal to total purchase payments increased by 5% annually, adjusted for withdrawals, prior to target date, adjusted for withdrawals and subsequent payments made since that date. If withdrawals are less than 5% of death benefit Issuer will reduce benefit base by dollar amount; if withdrawals are taken after target date or in excess of 5% of death benefit, excess portion of withdrawal will reduce benefit base in same proportion. Target Date is later of - 1) contract anniversary following owner's 80th birthday; or 2) 5th contract anniversary. Owner or Annuitant must participate in Asset Allocation Program and select one of asset allocation models.