Greater of 6-1/2% Roll-Up to Age 85 or Annual Ratchet to Age 85 Enhanced Death Benefit

Available during accumulation phase. Upon death of owner, benefit will be greater of - 1) 6-1/2% (4% for WA) Roll-up to Age 85, or 2) Annual Ratchet to Age 85. 6-1/2% (4% for WA) Roll-up to Age 85 is equal to total purchase payments plus daily roll-up adjusted for withdrawals, prior to owner's 86th birthday. Effective annual roll-up rate credited to benefit base is 6-1/2% (4% for WA) of variable account value (3% for some selected sub-accounts and fixed account value). Annual Ratchet to Age 85 is equal to greater of - 1) total purchase payments, or 2) highest contract value on any contract anniversary prior to owner's 86th birthday adjusted for withdrawals and subsequent payments. Upon election with Guaranteed Minimum Income Benefit, Owner may elect to reset Roll-Up benefit base on any contract anniversary prior to age 76.