Highest Daily Guaranteed Return Option

Benefit protects from poor investment performance during accumulation phase and guarantees. Benefit base is equal to contract value, adjusted for withdrawals and subsequent payments. Benefit provides a series of separate guarantees based on contract value. Each guarantee remains in existence until date on which it matures. Initial guarantee is created at rider issue, thereafter, a new guarantee will be created. With respect to such subsequent guarantee, highest account value that occurred between that rider anniversary and rider issue date will be identified. Issuer offers Optional 90% Cap Feature for Highest Daily GRO with this benefit, which will replace Transfer Calculation.