Guaranteed Minimum Death Benefit

Available during accumulation phase. Upon death of owner, benefit will be greatest of the 1) contract value or surrender value, whichever is greater; 2) total purchase payments adjusted for withdrawals accumulated at 5% annually, until earlier of - i) age 85, or ii) death, increased by purchase payments and reduced for withdrawals made since that date; or 3) greatest anniversary value. Greatest anniversary value is equal to highest contract value calculated on any contract anniversary, prior to age 81, increased by purchase payments and reduced for withdrawals made after reset date. Withdrawals will reduce death benefit by dollar amount if owner withdraws up to and equal to 5% of total purchase payments adjusted for withdrawals any excess withdrawal will reduce death benefit in same proportion.