Earnings Enhancement Benefit

Available during accumulation phase. Upon death of owner, Issuer will add 40% of earnings (25% if owner ages between 71 to 75) to any death benefit payable under contract. Earnings are amount by which sum of contract value exceeds remaining purchase payments. Issuer may not pay earnings in case adjusted purchase payments exceeds contract value. 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 equal to annual percentage rate of EEB charge multiplied by contract account value, 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 EEB benefit.