Highest Anniversary 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 anniversary value. Initially highest anniversary value is equal to contract value, thereafter on any contract anniversary, equal to greater of - 1) previous highest anniversary value, or 2) contract value on each anniversary prior to target date adjusted for withdrawals and subsequent payments made since that date. Target date is later of - 1) contract anniversary following owner or annuitant's 80th birthday, or 2) 5th contract anniversary. Owner must participate in Asset Allocation Program and select one of asset allocation models.