Annual Step-Up Death Benefit

Available during accumulation phase. Upon death of owner or annuitant, benefit will be greatest of -1) contract value; 2) purchase payments adjusted for withdrawals; or 3) highest anniversary value. Highest anniversary value initially equals initial purchase payment, thereafter on any anniversary prior to owner's 81st birthday, will be recalculated and set equal to greater of highest anniversary value prior to recalculation or contract value. Contract Owners having non-qualified plans have an additional feature of controlled payout plan, where they can decide the time period for receiving the benefit by beneficiaries after their death.