Greater of 6% Roll-Up to Age 85 or Annual Ratchet to Age 85 Enhanced Death Benefit

Available during accumulation phase. Upon death of owner, benefit will be greater of - 1) 6% Roll-up to Age 85 or 2) Annual Ratchet to Age 85. 6% Roll-up to Age 85 equals - 1) initial purchase payment and any subsequent purchase payment made plus 2) daily roll-up adjusted for withdrawals, prior to owner's 86th birthday. Effective annual roll-up rate credited to benefit base is 6% of variable account value (3% for some selected sub-accounts and fixed account value). Annual Ratchet to Age 85 is equal to greater of - 1) total purchase payments or 2) highest contract value on any contract anniversary, prior to owner's 86th birthday adjusted for withdrawals added to any purchase payments made. Owner may elect to reset Roll-Up benefit base on any contract anniversary prior to age 76, if elected with Guaranteed Minimum Income Benefit. For a limited time, Issuer is offering to increase the contract value and basic death benefit amount in return for terminating the rider. Issuer determines offer amount using standard actuarial calculations for determining contract reserves. Contract reserve for benefit is the difference between the present value of expected benefit claims less the present value of expected benefit charges. Issuer will calculate the actuarial value of GMDB and EEB separately. Amount of the offer is approximately 70% of actuarial valuation. Each of the benefit calculations is subject to a minimum offer, which is equal to annual percentage rate of GMDB charge multiplied by the GMDB benefit base, multiplied by two. If calculated actuarial value is less than minimum offer amount, minimum offer amount will apply. Actuarial value takes into account - 1) owner/annuitant's life expectancy (based on gender and age), 2) current and projected contract value and 3) current and projected GMDB benefit.