Highest Daily 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, or 3) Highest Daily Value. Initially highest daily value is equal to purchase payment, thereafter on any valuation day, equal to greater of - 1) previous highest daily value, or 2) contract value on each valuation day prior to target date adjusted for withdrawals and subsequent payments made since that date. 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. Please see prospectus for details.