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 must participate in Asset Allocation Program and select one of asset allocation models.