Guaranteed Minimum Death Benefit

Available during accumulation phase. Upon death of owner, benefit will be equal to - 1) GMDB roll-up, 2) GMDB step-up, or 3) greater of GMDB roll-up and GMDB step-up. GMDB roll-up is equal to total purchase payments accumulated daily at 5% (3% if owner is between age 81 to 85 at contract issue) annually adjusted for withdrawals, prior to later of - 1) owner's 80th birthday, or 2) 5th contract anniversary, adjusted for withdrawals and subsequent payments made since that date. If withdrawals are less than 5% (or 3%) of death benefit Issuer will reduce benefit base by dollar amount; if withdrawals are taken in excess of 5% (or 3%) of death benefit, excess portion of withdrawal will reduce benefit base in same proportion. GMDB Step-Up is equal to total purchase payments adjusted for withdrawal. GMDB step-up on each contract anniversary will be greater of previous GMDB step-up and contract value, prior to later of - 1) owner's 80th birthday, or 2) 5th contract anniversary, adjusted for withdrawals and subsequent payments made since that date. If owner is between age 81 to 85 at contract issue, GMDB step-up prior to 3rd contract anniversary is equal to total purchase payments, reduced by withdrawals. On 3rd contract anniversary, Issuer will set GMDB step-up to greater of - 1) current GMDB step-up, or 2) contract value, thereafter, increased by purchase payments and adjusted for withdrawals. Withdrawals will reduce GMDB step-up in same proportion. Please see prospectus for details.