Purchase Payment Accumulation Death Benefit

Available during accumulation phase. Upon death of owner, benefit will be greatest of - 1) contract value, 2) net purchase payments accumulated at 4% annually (3% if owner is 70 or older birthday ) until death adjusted for withdrawal, or 3) contract value calculated on seventh contract anniversary adjusted for withdrawals and subsequent payments. There is an Extended Legacy Program, offered by issuer, for beneficiaries to continue the contract after the death of the owner. The program is not available under rollover contracts and with any other than 5-year settlement option. Upon election, beneficiary may choose to receive the death benefit under either 1) a 5-year settlement option (starting from death of owner); or 2) in the form of withdrawals for a longer period of time. Issuer will charge the beneficiary an annual base contract expense of 1.15%. This charge is deducted daily from the average daily ending net asset value allocated to the Variable Portfolios.