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) unadjusted contract value, or 3) highest anniversary value. Initially highest anniversary value is equal to unadjusted contract value, thereafter on any contract anniversary, equal to greater of - 1) previous highest anniversary value, or 2) unadjusted 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's 80th birthday, or 2) 5th contract anniversary. Owner must participate in Asset Allocation Program.