5% Roll-Up Death Benefit

During accumulation phase, upon death of owner, benefit will be greatest of - 1) contract value, 2) purchase payments, or 3) GMDB benefit base, which is step-up value on rider effective date increased by purchase payments less any withdrawals, compounded at 5% (4% if owner is age 70 or older on rider effective date or 3% for state WA) annually from rider effective date to contract anniversary immediately preceding owner's 81st birthday. If contract value is greater than GMDB benefit base on earlier of 7th contract anniversary following rider date or contract anniversary prior to owner's 81st birthday, step-up date is set equal to that contract anniversary, and step-up value is set equal to contract value on that step-up date. For total withdrawals up to 5% of GMDB Benefit Base, withdrawal adjustment is dollar amount of withdrawal, after processing applicable dollar for dollar portion of withdrawal, withdrawal adjustment for total withdrawals in a contract year in excess of 5% of GMDB Benefit Base is in same proportion.