Greater of GMDB I

Available during accumulation phase. Upon death of owner, benefit will be greater of -1) Roll-up benefit base, or 2) Highest Anniversary Value benefit base. Highest Anniversary Value benefit base will depend on whether withdrawals are taken from contract. If no withdrawals have been taken, benefit base is greater of - 1) initial and subsequent purchase payment, or 2) highest account value on any contract anniversary until owner's 85th birthday. If withdrawals are taken from the contract, highest anniversary value benefit base will be reduced from the amount. At any time after a withdrawal, highest anniversary value benefit base is equal to the greater of - 1) highest anniversary value benefit base immediately following most recent withdrawal, or 2) highest account value on any contract anniversary after withdrawal and until owner's 85th birthday. Roll-up benefit base is equal to initial and subsequent purchase payment adjusted for excess withdrawal, plus Deferral bonus Roll-up amount or any Annual Roll-up amount minus a deduction that reflects any withdrawals up to Annual withdrawal amount. Deferral bonus Roll-up rate is 5% and is used to calculate amounts credited to Roll-up benefit base through end of the contract year that proceeds the contract year in which first withdrawal is made from the contract; and Annual Roll-up rate is 5% and is applicable after first withdrawal. Roll-up benefit base stops rolling up on contract anniversary following owner's 85th birthday. Issuer also provides Annual Withdrawal Amount beginning in 2nd contract year, and is equal to - 5% (Annual Roll-up rate), multiplied by Roll-up benefit base as of most recent contract anniversary. If owner elects to reset Roll-up benefit base under Guaranteed Minimum Income Benefit I - Asset Allocation, Greater of GMDB I will automatically get reset. Owner must participate in Asset Allocation Program.