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CORRESP
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CORRESP

 December 6, 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 on December 4 and 5, 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

 Comment: In the fifth sentence of the second paragraph, statement in parenthesis, please remove the reference to Annual Fees because it is
not a Crediting Method.

 Response: Revised as requested.

Comment: In the fifth sentence of the fourth paragraph, add that available Indexed Accounts may be changed at any time “after the end of the first
Segment term.” Also, clarify that the Index Accounts that will always be offered may not be identical to the ones offered in this prospectus.

Response: Revised to read:

 We can change the available
Indexed Accounts at any time on or after the first Contract anniversary; however, We will always offer at least 5 Indexed Accounts (but they may be different than the ones currently offered) and We guarantee that We will never offer a Buffer lower
than -2.5% for the life of Your Contract. In such case, if You invest in an Indexed Account with a -2.5% Buffer and hold the Segment until the maturity date, You could
lose up to 97.5% of your investment in that Segment.

 Comment: For the Indexed Accounts you will offer in the future, add minimum guarantees for
all offered features. This should be added to the cover page and all other applicable prospectus

disclosure (e.g., Risk section, Indexed account substitutions, Cap and Upside Participation Rates descriptions in the Crediting Methods).

Response: Revised as requested. See revised paragraph in response to the comment above.

Comment: Remove the seventh sentence in the fifth paragraph, (If You make an allocation to this Indexed Account and the Index loses 100% of its value
during the term, your risk of loss is 90%.) This is disclosed in the other sections of the prospectus.

 Response: Revised as requested.

Comment: In the second sentence of the fifth paragraph, add that Surrenders, including Income Choice monthly payments may be subject of Surrender
Charges…….”

 Response: Revised to read:

Surrenders (including Income Choice monthly income) may be subject to Surrender Charges, income taxes, market value adjustments and may
have other tax consequences, including federal and state income taxes.

 Comment: Revise the parenthetical in the fifth sentence of the fifth
paragraph to add RMDs and total free amounts.

 Response: Revised as requested.

Comment: We suggest the following organizational changes to the fifth paragraph:

Move the sentence below in front of the paragraph starting with “In addition….” and start a new paragraph.

You could lose up to your entire investment “and prior earnings” due to the Segment Value calculation and/or a negative Market Value Adjustment.

In addition, the Investment Base for each Segment will be reduced proportionally based on the percentage of Segment Value that is surrendered or deducted
(i.e., the Investment Base is reduced by more or less than the dollar amount surrendered/deducted depending on whether the Segment Value is less than or greater than the Investment Base).

Response: Revised as requested.

 Comment: In the
second sentence of the sixth paragraph, remove the statement in the parenthetical, and add how surrenders before the end of Surender Charge period and MVA period or if you intend or need to take partial surrenders or withdrawals during the
Segment term due to imposition of a Segment Value adjustment.

 Response: Revised to read:

This Contract is not for You if You are looking for a short-term investment and You plan to take surrenders before the end of the
Surrender Charge period and MVA period or if you intend or need to take full or partial surrenders during a Segment due to the Segment Value calculation.

 Comment: The sentence, “In addition to a Surrender Charge, a Market Value Adjustment will
apply to all surrenders from Indexed Accounts (except Income Choice monthly income) during the MVA period, including the Total Free Amount.” should be moved and placed as a third sentence in the fifth paragraph.

Response: Revised as requested.

 Summary

 Investment Options

 Comment: Revise
last paragraph and apply all changes you have made to the same statement on the cover page.

 Response: Revised as requested.

Automatic Rebalancing

 Comment: In the
first and the last sentence of the first paragraph, remove the parenthetical “(after the Surrender charge period or after a spousal continuation)”. Our understanding is that the Interim Account is used in more instances as explained in the
Interim Account section.

 Response: Revised as requested.

If you have any questions concerning responses to the comments, please contact me at (612) 678-5337.

Sincerely,

/s/ Nicole D. Wood

Nicole D. Wood

Assistant General Counsel and

Assistant Secretary

  The information in this Prospectus is not complete and may be changed. We may not sell these securities until the registration statement filed with the Securities and Exchange Commission is effective. This Prospectus is not an offer to sell these securities and it is not soliciting an offer to buy these securities in any state where the offer or sale is not permitted.

Prospectus

 XX XX, 2023

RiverSource®

Structured Solutions 2SM annuity

Single Purchase Payment Deferred Index-Linked Annuity Contract and Interests therein

  

  Issued by:

  RiverSource Life Insurance Company (RiverSource Life)

  70100 Ameriprise Financial Center

 Minneapolis, MN 55474

 Telephone: 1-800-862-7919

 (Service Center)

 RiverSource Account MGA

 This prospectus contains important information that You should know before investing in the
RiverSource Structured Solutions 2 annuity contract (the Contract) issued by RiverSource
Life Insurance Company (“RVS Life”, the “Company”, “us”, “we” or “our”). The Contract is a single premium deferred
index-linked annuity designed to help You invest on a tax-deferred basis and meet long-term financial goals. Please read this prospectus before investing and keep it for future reference.
You can purchase a Contract if You are age 90 or younger. The Company does not allow additional purchase payments after the Contract is issued.
You may allocate Your purchase payment to one or more of the index-linked investment options (Indexed
Accounts) available under the Contract. The Contract is an insurance product and is not an investment in a mutual fund or exchange-traded fund (“ETF”) that tracks an
index. Each Indexed Account has an applicable Crediting Method (with applicable Cap, Upside Participation Rate, Contingent Return and/or Annualized Income
Rate), a Buffer or Trigger (if the Index Performance is negative) and is tied to published index(es) or an exchange traded fund (both described as an Index). See “Investment
Options – Indexed Accounts - Indexed Account Options Table” for more information. The Indices used are price indices and performance of the Indexes do not reflect
dividends paid on the underlying stocks. The performance of ETF does not reflect dividends or other distributions declared by the ETF.
 Each time You make an allocation to an Indexed Account, a segment within the
Indexed Account (Segment) is created. The value of each Segment will change daily, positively or negatively, and can reflect significantly less gain or more
loss than would be applied on the date the Segment ends (Segment Maturity Date). We
determine the Segment Value prior to the Segment Mgaturity date using a formula that does not directly reflect the actual performance of the applicable Index, but rather determines the value of a hypothetical portfolio of instruments (including derivatives and
fixed assets) that provides the Segment Value at maturity.  On the date a Segment ends, the rate of return (which may be positive, negative, or zero) for each Segment is based on the Index performance and Crediting Method of the Indexed
Account. A Cap (declared maximum rate of return when the Index return is positive) or Contingent Return (predetermined rate of return if Index return does not have a loss that
exceeds the protection level) may limit the Segment rate of return, and You may earn less than the full amount of positive Index returns. Upside Participation Rates are always 100% or greater so they will not limit the upside return. Income Choice options provide monthly income based
on the Annualized Income Rate in lieu of any upside returns. See “Valuing Your Investment” and “Crediting Methods” for an explanation of how Your Contract
Value and Segment Value is determined. You bear the risk of potential loss of principal and any related earnings including any 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 of loss and You may lose all or a portion of Your investment The extent of this loss will vary based on the protection option (Buffer
or Trigger) and the level of protection you choose. With a Buffer, You only incur the portion of the Index loss that exceeds the Buffer percentage. With a Trigger, You incur the full loss if the Index return is negative and exceeds the
Trigger percentage. On the Segment Maturity Date, protection options can have a maximum loss of 75% to 100% (if the Index loses 100% of its value during the term); however, there is one Indexed Account with -100% Buffer protection which
can prevent a loss on the Segment Maturity Date. See “Investment Options – Indexed Accounts - Indexed Account Options Table” for a list of Indexed Accounts and
the maximum loss as of the Segment Maturity Date. Surrender Charges, Market Value Adjustments and any fees can increase the loss. See “Risk Factors”, and
“Contract Fees, Charges, and Value Adjustments” for more information.

 RiverSource Structured Solutions 2 annuity —
Prospectus 1

 Transfers, including
any automatic transfers for the optional automated transfer program, can only occur on contract anniversaries. You can provide instructions to transfer the Segment Value as of
the Segment Maturity Date to any available Indexed Account (or to the Interim Account after the Surrender Charge period or after a spousal continuation). See “Investment Options - Interim Account” section for more information. If no transfer instructions are received and You have not elected automatic rebalancing, the Segment Value will renew into a new Segment for the same Indexed Account
(if no longer available, the Segment Value will be transferred to the Interim Account). We can change the Cap, Contingent Return, Upside Participation Rate, Annualized Income
Rate, and Annual Fee for new Segments. We can change the available Indexed Accounts at any time on or after the first Contract anniversary; however, We will always offer at least 5 Indexed Accounts (but they may be different than the ones currently offered) and We guarantee that We
will never offer a Buffer lower than -2.5% for the life of Your Contract. In such case, if You invest in an Indexed Account with a -2.5% Buffer and hold the Segment until the maturity date, You could lose up to 97.5% of your investment in that
Segment. There is no guarantee a Trigger protection option will always be available. See “Transfers” and “Investment Options – Discontinuation and Substitution of Indexes and Indexed Accounts” for more information.

 You are permitted
to take partial and full surrenders at any time before the date on which annuity payments begin (Annuitization Start Date). Surrenders (including Income Choice monthly income)
may be subject to Surrender Charges, income taxes, market value adjustments and may have other tax consequences, including federal and state income taxes. In addition to a Surrender Charge, a Market Value Adjustment will apply to all surrenders from Indexed Accounts
(except Income Choice monthly income) during the MVA period, including the Total Free Amount. A Market Value
Adjustment (MVA) may result in both upward and downward adjustments in surrenders and amounts applied to an
annuity payment plan. A positive MVA can increase the death benefit (but an MVA will not decrease the death benefit). See “Market Value Adjustments” for more information. Before the Segment Maturity Date, the amounts available for full or partial surrenders (including required minimum distributions and total free amounts, excluding Income Choice monthly
income), death benefit payments, or annuitization payments are subject to the Segment Value calculation, which could significantly reduce the amount available for these actions.
This also means the Segment Value could be less if any of these actions happen during a Segment rather than if You held the Segment until the Maturity Date and the full protection is reflected. You could lose up to your entire investment and any prior earnings due to the Segment
Value calculation and/or a negative Market Value Adjustment.

In addition, the Investment Base for each Segment will be reduced proportionally based on the percentage of
Segment Value that is surrendered or deducted (i.e., the Investment Base is reduced by more or less than the dollar amount surrendered/deducted depending on whether the Segment Value is less than or greater than the Investment Base).
Adjustments to the Investment Base will lower the Segment Value going forward. You should carefully consider whether You should purchase this Contract if You intend to take partial surrenders before a Segment Maturity Date or prior to the
end of the applicable Surrender Charge and MVA period. See "Segment Value after the Segment start date and before the Segment Maturity Date" for more information.

A discussion of risk factors associated with the contract begins on
page __ of the prospectus.
This Contract is not for You if You are looking for a short-term investment and You plan to take surrenders before the
end of the Surrender Charge period and MVA period or if you intend or need to take full or partial surrenders during a Segment due to the Segment Value
calculation.

 Investment in the Contract involves
investment risks, including possible loss of principal and previous earnings on prior and current Segments.
The Contract does not provide tax deferral benefits, beyond those already provided under the Internal
Revenue Code, for a Contract purchased as a Qualified Contract, such as an Individual Retirement Annuity (“IRA”). Amounts withdrawn from the Contract prior to age 59
1/2 may also be subject a 10% IRS penalty. Investors should consult with their tax advisor for more information.
 You may cancel the Contract within a certain number of days (varies by state but
not less than 10 days) after you receive it. If you cancel your Contract during this period, We will issue a refund and you will not be subject to a Surrender Charge or Market Value Adjustment. Your state’s law will determine the amount you will receive and the
length of time to request the refund. See “Right to Examine and Cancel” and “Appendix A: State Variations” for more information.
All guarantees under the Contract are obligations of RiverSource Life and are subject to
the creditworthiness and claims-paying ability of RiverSource Life.
The
principal underwriter of the Contract is RiverSource Distributors, Inc. The offering of the Contract is intended to be continuous.

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