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CORRESP
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CORRESP

 November 29, 2023

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

 Initial Registration Statement on Form S-3

 File No. 333-273966

Dear Mr. Cowan:

 On behalf of RiverSource
Life Insurance Company (the “Company”), we are responding to the additional comments of the Securities and Exchange Commission provided to us orally on November 17, 2023, with regard to the Registration Statement referenced above.
Along with this letter, we are filing a revised prospectus, which reflects conforming edits.

 Comments and responses are outlined below.

Cover Page

 1. In the fifth sentence of second
paragraph, please clarify Crediting Methods applicable to each Indexed Account and specify all Crediting Methods (Caps, Upside Participation Rate or Contingent Return, Annualized income rate, if performance is positive, and Buffer or Trigger if
performance is negative)

 Response: Revised as requested.

2. In the last sentence of the second paragraph, please revise to state that the performance of ETF does not reflect dividends or other distributions declared
by the ETF.

 Response: Revised as requested.

3. In the third sentence of the third paragraph, add that the Segment Value is determined prior to the maturity date.

Response: Revised as requested.

 4. In the third
paragraph, when discussing that Cap and Contingent Return may limit the Segment rate of return, please reference Upside Participation and other upside rates here.

Response: The following clarification is added:

Upside Participation Rates are always 100% or greater so they will not limit the upside return. Income Choice options provide monthly income in
lieu of any upside returns.

 5. In the third paragraph, please add that You will bear a greater or lesser risk of loss and You may lose
all or part of Your investment.

 Response: Revised as requested.

6. In the fourth paragraph discussing transfers, please add that “Transfers, including any automatic transfers for the optional automated transfer
program, can only occur on contract anniversaries.”

 Response: Revised as requested.

7. In the same paragraph, please explain and describe why the Interim Account may or may not be available. You can add this explanation to the section
describing the Interim Account elsewhere in the prospectus. This should be cleared throughout the prospectus – explain that this is a holding account and add cross reference to that section.

Response: Revised as requested.

 8. In the same
paragraph, clarify default options if no transfer instructions are received.

 Response: Revised as requested.

9. In addition to the number of indexed accounts that would be offered, clarify the terms of the offering, i.e., describe the minimum protection that would be
available from the buffer or trigger associated with those indexed accounts. Add the contractual minimums that would be associated with the indexed accounts for the life of the contract. Address the maximum percentage an investor could lose. This
should be included wherever there is disclosure relating to the right to remove or add indexed accounts, including in the risk disclosure.

 Response:
Revised as requested.

 10. In the second sentence of the fifth paragraph discussing surrender, add that Surrenders may be subject to Surrender
Charges, income taxes, market value adjustments and may have other tax consequences, including federal and state income taxes.

 Response:
Revised as requested.

 11. In the same paragraph, when discussing amounts available for full or partial surrenders before the Segment Maturity date,
should this include “of monthly income” as a third item. Also, make sure all transactions subject to adjustment are included in this parenthetical “including required distribution amounts and the total free amount” - everything
that is part of the segment value calculation confirm that there is nothing missing.

 Response: Revised to exclude monthly income since that does not vary based on the Segment Value
calculation.

 12. Please add maximum loss from Segment Value adjustment and MVA if withdrawal, surrender or other such transaction is taken before the
Segment Maturity date (i.e. “you could lose 100 percent of your entire investment”).

 Response: Revised as requested and added the
following:

 You could lose up to your entire investment due to the Segment value calculation and/or negative market value adjustment.

13. The paragraph regarding elective lock and automatic lock features can be removed.

Response: The paragraph regarding elective lock and automatic lock features is removed from the cover page.

14. in the second to last paragraph, discussing right to examine and cancel contract, add a cross reference to Appendix for state variations.

Response: Revised as requested.

 Summary

 15. In the Purpose paragraph, I the second sentence, please clarify that you can take partial or full surrender.

Response: Revised as requested.

 16. In the Investment
Options, in the table with Index categories, please specify upside options for each along with minimum guaranteed rates applicable to each.

 Response:
We have added a cross reference to the Indexed Account Options table in the “Investment Options – Indexed Accounts” section of the prospectus.

17. In the paragraph following the Index table, please add that The Indices used are price indices and do not reflect dividends paid on the underlying stocks
or ETF in the case of iShares U.S. Real Estate ETF.

 Response: Revised as requested.

18. In the last paragraph, add disclosure regarding 10 indexed accounts and minimums guaranteed.

Response: Revised as requested.

 19. In the Segment
Value, second paragraph, please specify maximum loss as to Buffer and Trigger options, respectively.

 Response: Revised as requested.

 20. In the Transfers, first paragraph, third sentence, what does mean that “If You are using the optional
automated transfer program, the Contract Value that can be transferred will be reduced for any amounts that are transferred automatically to the Interim Account.” Please better explain the Interim Account and how it is used.

Response: This sentence has been removed and explanation is added to the next paragraph.

21. In the Surrenders, when discussing partial or full surrender please also mention the other transactions that will be subject to Segment Value adjustment
(i.e. death benefit, free withdrawals, annuitization, applicable fees and charges, RMDs, monthly income, etc).

 Response: Revised as requested.

 22. In the Surrender Charges and Market Value Adjustment sections, revise to include that partial or full surrenders may be subject to a surrender
charge.

 Response: Revised as requested.

 Risk
Factors

 Liquidity

 23. In the fourth
paragraph, in the reservation of right disclosure, revise to add that “We reserve the right to limit how much of the Contract Value can be allocated among the……”

Response: Revised as requested.

 Risk of Loss –
Segment Value Prior to Maturity

 24. In the first paragraph when discussing the substantial risk of loss with all but one Indexed Account, add a
sentence for the maximum percentage loss with respect to each Indexed Account.

 Response: The sentence is revised to read:

There is a risk of substantial loss, which could be as much as 100% depending on the indexed account (if the underlying index loses 100% during
the term). For the maximum percentage loss with respect to each Indexed Account, see “Indexed Account Options” table.

 25. In the last sentence
of the first paragraph, specify maximum loss here, too the maximum loss could be as much as 100 percent.

 Response: The maximum loss is
specified in the revised sentence, as stated above.

 26. Revise last two sentences in the last paragraph, to cover Trigger and Buffer and that it is
possible that there is no protection.

 Response: Revised as requested.

 Caps, Contingent Returns, Annual Fees and Limits to Positive Returns

27. Since you offer Upside Participation rate too, add applicable disclosure related to Upside Participation rates to the Caps, Contingent Returns, Annual Fees
and Limits to Positive Returns section

 Response: Upside participation rate is guaranteed to be 100% or more so it will never limit the positive
return, only increase it, so no disclosure was added.

 28. In the third sentence of the second paragraph, replace “may” with “will”.

 Response: If Index return is already greater than Cap, it will not lower Segment return. Also, if Index return is between zero and Buffer, it will
not lower the return. Therefore, the “may” is replaced with “will generally”.

 We may Discontinue or Substitute an Index

29. If we substitute an alternative Index remove “then the Segment value may change to reflect the new Index” and insert: If We substitute an
alternative Index . . . “ before the Segment Maturity date, we will calculate the index rate of return for the full segment using the replaced index up until the replacement date and the new index thereafter through the segment maturity
date”

 Response: Revised to read:

If We substitute an alternative Index before the Segment Maturity Date, We will calculate the Index rate of return for the Segment using the
original Index up until the substitution date and the new Index from the substitution date to the Segment Maturity Date.

 30. In the second paragraph, add
that the Index rate of return will be calculated for the full Segment using the replaced Index rate up until the replacement date and the new Index rate thereafter through the Segment Maturity Date. Also, add that if no reasonable alternative is
available for substitution of such Index, then the Segment will terminate as of specified date and daily Segment Value calculation will no longer occur and the Segment value will not change until the next Contract Anniversary. Clarify if there is
any interest factored in, any negative or positive credit at the end of Segment Maturity Date and clarify that the Segment value calculation will no longer occur.

Response: The paragraph is revised to read – revisions underlined:

If We substitute an alternative Index before the Segment Maturity Date, We will calculate the Index rate of return for the
Segment using the original Index up until the substitution date and the new index from the substitution date to the Segment Maturity Date. See “Discontinuation and Substitution of Indexes and Indexed
Accounts” provision for how the Index return will be calculated when an Index is substituted. If no reasonable alternative is available for substitution of such Index, then the daily Segment Value calculation will no longer occur, and
the Segment value will not change until the next Contract Anniversary (unless a surrender is taken from that Segment) when the Segment will end. In this case, the Segment Maturity date will be changed to the next contract anniversary; however, no
interest will be credited, and the Segment rate of return will not

be calculated and applied as described in the Segment Value On The Segment Maturity Date provision. We will notify You before the discontinuation. The Crediting Method will not change
during a Segment. You must transfer the Segment value to any available Indexed Accounts or the Interim Account (after the surrender charge period or after a spousal continuation) during the next transfer window.

We May Discontinue an Indexed Account at Maturity

 31. In
the last sentence, clarify whether these 10 indexed accounts could be different from what is currently offered. Based on resolution to earlier comment regarding minimum buffer percentage.

Response: Revised as requested.

 Level of Interest
Rates, Caps, Contingent Returns, Upside Participation Rates, Annualized Income Rates and Annual Fees

 32. Please add response disclosure from the
Comment 61, as stated in the initial comments.

 Response: In response to Comment 61 in our initial responses, since this section does not discuss
protection options, we noted that new disclosure addressing the Comment 61 is added to the “Risk factors - Risk of Loss in Indexed Accounts – Index Performance” section, as we think it better fits as part of this risk:

For Segments with a duration longer than one year (except for Annual Lock with Buffer Crediting Method), the applicable Buffer or Trigger are
for the duration of the Segment and are not applied on an annual basis.

 Locking the Segment Value

33. In the newly added bullet, second sentence strike the word “certain” from the exception for the Dual Directions Segments.

Response: Revised as requested.

 The Annuity Contract
- Considerations for investment only pooled defined benefit plans under Section 401(a) of the Code

 34. Fees and Expenses should be moved down
under Contract Fees, Charges and Value Adjustments.

 Response: Since the fees and charges are already described in the Contract Fees, Charges, and
Value Adjustments section, the reference to the other provision was added, as shown below:

 For an explanation of the fees and expenses
that apply to this contract, see the Contract Fees, Charges, and Value Adjustments provision.

 Contract Fees, Charges and Value Adjustments

35. Remove sentence below the heading.

 Response: Revised
as requested.

 Indexed Account Fees and Transaction Costs

36. In the first paragraph, please clarify whether the Annual Fee is deducted only on the Segment Maturity Date, even for multiple year Segments (unless
surrender or other transactions during the term).

 Response: Revised as requested.

37. In the second paragraph, please disclose the maximum percentage loss an investor could sustain as a result of the interim Segment Value calculation

Response: Revised as requested.

 Market Value
Adjustments

 38. Please add the maximum loss on MVA. If the worst case is that an investor could lose 100 % of the investment including prior
credited interest, state that.

 Response: It’s mathematically impossible for the MVA to cause a 100% loss since it’s a ratio based on the
change in the interest rates. You would have to know the maximum interest rate change that could happen in a short period of time to know the maximum loss that the MVA could create. We have moved the last two sentences of the first paragraph to
right before the Discontinuation of MVA Index section, and added the following examples:

 If there is a significant increase in interest
rates since the contract is issued, You could experience a significant negative MVA for any surrenders or when Annuity Payments start. However, the negative MVA for a given interest rate increase will decrease as You get closer to the end of the MVA
period and there is no MVA after the MVA period ends. See table below.

 Examples of MVA Factor for 6-Year Surrender
Charge

 Duration

After Issue

 Reference Rate on

Contract Date (i)

 Current Reference

Rate (j)

(k)

 MVA

Factor

 #1

1 Day

1%

2%

6.00

-5.7%

 #2

1 Day

1%

3%

6.00

-11.1%

 #3

1 Day

1%

11%

6.00

-43.2%

 #4

1 Day

1%

31%

6.00

-79.0%

 #5

1 Day

1%

51%

6.00

-91.0%

 #6

2 Years

1%

51%

4.90

-86.1%

 #7

4 Years

1%

51%

3.46

-75.2%

 39. Revise first paragraph to add that the MVA may be applied to death benefit as well. Also add that, the MVA
applies even to surrenders and other such transactions that occur on Segment Maturity date, except as provided below.

 Response: The following
revisions are made:

 A Market Value Adjustment (MVA) is a positive or negative adjustment that may be applied during the MVA Period, when a full or
partial surrender (including the total free amount and required minimum distributions) is taken, when Annuity Payments start or death benefit is paid. An MVA may increase the death benefit but will not decrease it. If the MVA is
posi