Combination Roll-up and Highest Quarterly Anniversary Value GMDB

Available during accumulation phase. Upon death of owner, benefit will be greatest of - 1) contract value, 2) purchase payments, or 3) GMDB benefit base. GMDB benefit base is greater of - 1) roll-up component, or 2) highest quarterly anniversary value component. Roll-up component initially equals greater of - 1) initial purchase payment, or 2) contract value adjusted for charges and deductions, increased by purchase payments less any withdrawals, compounded at 5% annually, prior to owner's 81st birthday. Highest quarterly anniversary value component equals greater of - 1) contract value at issue, or 2) highest contract quarterly anniversary value calculated on any quarterly contract anniversary, prior to owner's 81st birthday, reduced for withdrawals and increased by purchase payments made. If contract value is greater than GMDB benefit base on earlier of 7th contract anniversary following rider date or contract anniversary prior to owner's 81st birthday, step-up date is set equal to that contract anniversary, and step-up value is set equal to contract value on that step-up date. For total withdrawals up to roll up % of GMDB Benefit Base, withdrawal adjustment is dollar amount of withdrawal, after processing applicable dollar for dollar portion of withdrawal, withdrawal adjustment for total withdrawals in a contract year in excess of the roll up % of GMDB Benefit Base is in same proportion.