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CORRESP
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CORRESP

 January 10, 2020

Mark Cowan

 Senior Counsel

Disclosure Review and Accounting Office

 Division of Investment
Management

 Securities and Exchange Commission

 100 F Street,
N.E. (Mail Stop 5-6)

 Washington, D.C. 20549

RE:
 RiverSource Life Insurance Company

    Registration Statement on Form S-3

    Pre-Effective Amendment No.1

    File No. 333-232973

  RiverSource® Structured Solutions annuity

Dear Mr. Cowan:

 We received comments from you on the 3rd, 5th, 17th, 20th, 23rd and 26th of December 2019 with respect to Registrant’s above-referenced Pre-Effective Amendment
No. 1 to Registration Statement on Form S-3 filed on Oct. 21, 2019.

 Comments and responses are
outlined below.

 COMMENTS RECEIVED DEC. 3, 2019

(Please note that subsequent Staff comments may have altered initial revisions.)

COVER PAGE

 Comment: In the first paragraph
please clarify that the purchase payments can be made for only 90 days and define the Contract Date.

 Response: Revised to read:

You can make purchase payments for only 90 days after the date the Contract is issued (Contract Date).

Comment: Please revise the second sentence of the third paragraph, if true, to include any credited earnings on prior Segments to the related earnings
and clarify that all investment may be lost and not just the portion.

 Response: Revised to read:

You bear the risk of potential loss of principal and any related earnings, including any credited earnings on prior Segments with respect to
investments in the Indexed Accounts. Depending upon which Indexed Account You select, You will bear a greater or lesser risk and You may lose all or a portion of Your investment.

 1

 Comment: Please clarify that surrenders can be full and partial and that the risk of loss of principal can
be due to the Segment Value calculation if the surrender is done on day other than the dates all of your Segments end.

 Response: Revised as
requested.

 DEFINED TERMS

 Comment:
Please revise the “Indexed Account” term to include the Crediting Method, duration and applicable Buffer or Floor for each Indexed Account will not change for the duration of the Contract

Response: Revised to read:

 Indexed
Account. An option available to which You may allocate the initial purchase payment and Contract Value. The Crediting Method, duration and applicable Buffer or Floor for each Indexed Account will not change for the duration of the Contract.

Comment: The definition for “Segment Value” should clarify if the portion or value is the right term.

Response: Revised to read:

 Segment
Value. The amount of Your Contract Value that is allocated to a Segment. The value fluctuates daily.

 SUMMARY

Comment: In the “Purpose” paragraph, second sentence, is it necessary to have a statement that additional purchase
payment can be made “Before the Annuitization Start Date”?

 Response: The sentence has been revised to read:

You can make additional purchase payments for 90 days after the Contract Date.

Comment: Also, revise the Contract risk disclosure to include risk of loss of previously earnings on prior Segments.

Response: Revised to read:

 This
Contract is not for You if You are looking for a short-term investment or if You plan to take surrenders (in excess of Total Free Amount) before the end of the Surrender Charge period. Investment in the Contract involves investment risks, including
possible loss of principal and previously credited earnings on prior Segments.

 2

 Buying Your Contract – Purchase Payments

Comment: In the “Buying Your Contract – Purchase Payments”, please disclose that the additional purchase payments are in the Interim
Account and this means you will not be able to invest in the Indexed Accounts or Fixed Account until the next Contract Anniversary and your additional purchase payments could earn as little as the 1% for the period prior to the Contract Anniversary.
Also, correct the typo in the second paragraph, second sentence to replace “or” with an “and” (…increase the Contract Value or the death benefit…)

Response: Revised as requested.

 Rate Lock

 Comment: In the “Rate Lock” description, please explain where the applicable rates, Caps, and Annual Fees are set forth and
whether they are posted on the website. If so, the website reference should be added. Also, please explain where the contractual minimum and maximums are set forth.

Response: Revised as requested.

 Right to Examine
and Cancel

 Comment: In the “Right to Examine and Cancel”, clarify if the refunded Contract Value amount is subject to Segment
Value adjustment.

 Response: Revised to add the following clarification:

Note: Any amount allocated to an Indexed Account will have its value based on the Segment Value calculation to determine that portion of the
Contract Value. [further revisions were made in response to subsequent comments]

 Comment: In the “Right to Examine and Cancel”, clarify
if the amount of refund for IRA and non- IRA depends upon the state? If so, revise to so state.

 Response:
Revised to clarify and added “subject to state law”. [further revisions were made in response to subsequent comments]

 Investment Options

 Comment: In the “Investment Options” summary, add the chart with all index options available.

Response: Currently, we offer 45 Indexed Accounts and chart with available indexed options is part of the section “Investment Options –
Indexed Accounts”. The purpose of the summary is to give a short description of main contract features and the lengthy description of the all available indexed accounts is inappropriate for a summary section. Instead, we have a reference to the
section with a more detailed disclosure about the available indexed accounts. “Each Index is described in more detail under the section titled “Indexed Accounts – Additional Information about the Indexes”. [subsequent comments
indicated this revision would not be necessary]

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 Comment: In the “Investment Options” summary, revise the last paragraph to delete “We
determine at Our sole discretion that Our use of the Index should be discontinued.” Also, clarify that even if change the Index, the Crediting Method applicable to the prior Index will apply to the new Index.

Response: Since this is a summary section of contract features, the last paragraph is revised to state:

Over the course of Your Contract, We may add, discontinue or substitute an Index. For details, see the sections titled “Risk Factors: We
May Discontinue or Substitute an Index” and “Investment Options - Additional Information about the Indexes.” Discontinuation and substitution disclosure was subsequently centralized under its own subheading.

Crediting Methods for the Indexed Accounts

Comment: In the “Crediting Methods for the Indexed Accounts” summary, revise to add that “We reserve the right to cease offering
Crediting Methods for renewal Segments.” Also, clarify that the notification of the available Indexed Accounts and applicable Crediting Methods will be send 14 days prior to the Contract anniversary and clarify if all Crediting Methods are not
available with each Index or with each Indexed account.

 Response: Revised to read:

We reserve the right to stop offering Crediting Methods. Before each Contract anniversary, We will notify You at least 14 days before each
Contract Anniversary of the available Indexed Accounts and applicable Crediting Methods if You have Contract Value that can be transferred on that Contract Anniversary.

Transfers

 Comment: In the
“Transfers” summary, make it clear that investor will not get renewal terms and Caps etc. until 14 days prior to Contract Anniversary, so they should wait until notice is received before requesting transfer.

Response: The following clarification is added:

Keep in mind that We will send You a notice of renewal rates, Caps and Annual Fees at least 14 days in advance of Your Contract Anniversary.
[additional disclosure subsequently added]

 Surrenders

Comment: In the “Surrender Charges” summary, explain what you mean by ‘the Contract loss”.

Response: The following clarification is added (underlined below):

The amount of the Surrender Charge, if any, will depend on the Contract Year during which the surrender is taken. At the time of a partial
surrender, if the Contract has a loss (i.e. Contract Value is less than purchase payments not previously surrendered), the Surrender Charge will be greater, and therefore the amount of Contract Value that needs to be surrendered is greater,
than if the Contract has a gain. The schedules below set forth the Surrender Charges under the Contract.

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 RISK FACTORS

Comment: This section should be revised.

Response: Revised as requested.

 Liquidity

 Comment: Please revise the “Liquidity” risk disclosure and:

•

 Add “that Your ability to react to changing market conditions is limited because You may only transfer
eligible Contract Value once each Contract Year during the Transfer Window” and with respect to amounts in the Indexed Accounts only at Segment Maturity.”

•

 Delete last two sentences in the third paragraph, because they do not belong into the Risk factors.

 Response: Revised.

Rate Lock

 Comment: In the “Rate
Lock” risk disclosure, clarify that if the Contract is not issued within 60 days of application, the person bear risk that rates, Cap etc. could decrease.

Response: This comment is no longer applicable due to major revisions to Risk Factors.

Index

 Comment: In the “Index”
risk disclosure, clarify whether Segment returns on iShares U.S. Real Estate ETF segments do not include dividends or other distributions declared by the Index Fund or ETF.

Response: Exclusion of dividends is addressed for all Indexes in Additional Information About the Indexes.

Index Rate of Return

 Comment: In the
“Index Rate of Return” risk disclosure,

•

 Add that You always assume the risk that the Index rate of return will not increase Your Segment Value and You
risk a loss of principal and previously credited earnings.

•

 Clarify the statement that “You also bear the risk that sustained declines in the relevant index may cause
the Index rate of return to not increase the Segment Value for a prolonged period.”

•

 Disclosure in the third paragraph states: “Before the Segment Maturity Date, there is a risk of loss of
principal due to the proxy value calculation even if the index has positive returns. For partial or full surrenders, there is a risk of loss of principal due to Surrender Charges even if the index has positive returns. For Segments with a duration
longer than one year, the declared Cap is for the duration of the Segment. The Cap would be lower if it was measured on an annual basis.” Please revise to state “Before the Segment Maturity Date,

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for partial surrenders or full surrenders, there is a risk of loss of principal due to the proxy value calculation even if the index has positive returns. There is also a risk of loss of
principal due to Surrender Charges even if the index has positive returns. For Segments with a duration longer than one year, the declared Cap is for the duration of the Segment (and is not calculated on an annual basis). The Cap would be lower if
it was measured on an annual basis.

 Response: The Risk Factors was revised in its entirety. Revisions were made where
applicable.

 Buffer and Floor

 Comment:
The “Buffer and Floor” risk disclosure states: “While the Buffer and Floor for each applicable Indexed Account is guaranteed and will not change, there is a risk Your rate of return could be negative and result in significant loss
even after the application of a Buffer or Floor.” Please add that the Buffer and Floor for each applicable Indexed Account is guaranteed for the duration of Your Contract.

Also, clarify that the statement: “The full protection of the Buffer or Floor is not realized until it matures”, means that if you take a withdrawal
or surrender prior to Segment maturity you will not get the protections of the Buffer or Floor.

 Response: Disclosure related to Buffers and Floors
has been revised throughout Risk Factors.

 Elective Lock

Comment: In the “Elective Lock” risk disclosure, all risks should be specified.

In the second bullet, clarify whether “full protection” means “any protection”.

Explain how the risk stated in the fourth bullet is a risk.

Response: Revised as requested.

 Segment Value

 Comment: In the “Segment Value” risk disclosure, proxy value formula need to be described in plain English and the actual formula
in the Appendix.

 Revise last paragraph.

 Response:
Segment Value and proxy value disclosure revised throughout.

 General

Comment: Add risk factor for limitation on additional payments.

Response: Limitations on Purchase Payments added to Risk Factors.

THE ANNUITY CONTRACT

 Comment: Consider
changing a header to this section to “Contract fees and Charges” since this section should disclose all contract fees and charges, including surrender charges.

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 Response: For clarity, we have added a subheading prior to the “Surrender Charges” disclosure:

 CONTRACT FEES AND CHARGES

Comment: The disclosure states that a death benefit may also be payable upon a death. Please clarify or delete since earlier disclosure states that the
death benefit is not paid after annuitization.

 Response: Revised to read:

Before the Annuitization Start Date, a death benefit may also become payable upon Your death. Under the Contract We promise to pay an income in
the form of annuity payments, beginning on the Annuitization Start Date. All payments under the Contract are subject to the terms and conditions described in this prospectus.

Surrender Charges

 Comment: In the
“Surrender Charges” section, clarify that partial and full surrender may be subject to surrender charges.

 Response: Revised to read:

 Partial surrenders and full surrenders may be subject to charges and income taxes (including an IRS penalty that may apply if You
surrender prior to You reaching age 591/2) and may have other tax consequences.

 Comment: The “Surrender Charges” disclosure states:
“At the time of a partial surrender, if the Contract has a loss, the Surrender Charge will be greater, and therefore the amount of Contract Value that needs to be surrendered is greater, than if the Contract has a gain. The schedules below set
forth the Surrender Charges under the Contract.” Please explain what this means based on Segment value proxy value calculation. Also, state why investor would pick one surrender charge value over the other and clarify whether the associated fee
is imposed.

 Response: The disclosure has been revised to address partial surrenders. A further explanation was added:

You select either a 6-year or 3-year Surrender Charge
schedule at the time of application. In general, interest rates and caps will be higher and annual fees will be lower, if you choose a 6-year Surrender Charge schedule.

PURCHASE

 Purchasing the Contract

 Comment: Please revise the last paragraph to clarify how does investor find out the applicable rates on application date. Specify that all
rates are on website. Investor should check these dates before signing application.

 Response: Revised as requested.

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 Allocation of Your Purchase Payments

Comment: In the “Allocation of Your Purchase Payments” section, please disclose that the additional purchase payments are in the Interim
Account and that you will not be able to invest in the Indexed Accounts or Fixed Account until the next Contract Anniversary and that your additional purchase payments could earn as little as the 1% for the period prior to the Contract Anniversary.

 Response: Revised to read:

 Any
additional purchase payments are held in the Interim Account earning daily fixed interest at a rate We declare periodically, but not less than 1% or the minimum rate required by state law. This means You will not be able to allocate additional
purchase payments to the Fi