Total Protection - Guaranteed Minimum Accumulation Benefit

Benefit protects from poor investment performance during accumulation phase. Benefit base depends on when benefit is added to contract; if benefit is added to contract at issue, benefit base equals to 105% of initial purchase payments, if is added to contract after contract issue, benefit base equals 105% of contract value; including any credit enhancement or bonus credit, increased by purchase payments made during 3 contract years and adjusted for withdrawals. Benefit guarantees that contract value will not be less than benefit base at rider maturity date. If contract value is less than benefit base at rider maturity date, Issuer will apply additional amount to increase contract value equal to benefit base.