Guaranteed Lifetime Withdrawal Benefit - Death Benefit

Benefit is only available in conjunction Guaranteed Lifetime Withdrawal Benefit. Upon death of annuitant, benefit will equal to initial purchase payment, increased by subsequent purchase payments made. If contract value on any annual step-up date is greater than current death benefit base, death benefit will automatically increase to an amount equal to contract value. If withdrawals are not excess withdrawals Issuer will reduce benefit base by dollar amount; if withdrawals are excess of annual benefit payments, benefit base will reduce to lesser of - 1) benefit base before withdrawal minus withdrawal, or 2) contract value after withdrawal. Highest Anniversary value will be calculated annually for state of NY. Owner must participate in Asset Allocation Program.