Return of Investment Death Benefit

Available during accumulation phase only. Upon death of owner (any annuitant for non-natural owners), benefit will be equal to the greater of - 1) Contract Value or 2) Total Adjusted Purchase Payments. If owner change, the total adjusted purchase payments will be reset to equal the lesser of -1) Contract Value as of the effective date of the Owner change or 2) Total Adjusted Purchase Payments as of Change Date. Withdrawals for advisory fees up to 1.5% of the Contract Value during the calendar year will not impact the Death Benefit Amount under the Benefit. Any advisory fee withdrawals that exceed this annual limit will result in a reduction of the Death Benefit Amount.