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CORRESP
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CORRESP

 December 20, 2021

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 (“Company”)

  RiverSource Variable Life Separate Account (“Registrant”)

  Initial Registration Statement on Form N-6

      File Nos.
333-260175/811-04298

   RiverSource Life
Insurance Co. of New York (“Company”)

   RiverSource of New York Account 8 (“Registrant”)

  Initial Registration Statement on Form N-6

  File Nos. 333-260322/811-05213

Dear Mr. Cowan:

 This letter is in response to the
Staff’s comments we received on December 10, 2021, for the above-referenced Initial Registration Statement filings which we filed on or about October 12, 2021 and October 18, 2021. Comments and responses are outlined below.

General

 Comment 1.

 Please confirm that all missing information, including all exhibits, will be filed in a pre-effective
amendment to each registration statement. We may have further comments when you supply the omitted information.

 Response: All missing information,
including all exhibits, will be filed in a pre-effective to each registration statement.

 Comment 2.

Please clarify supplementally whether there are any types of guarantees or support agreements with third parties to support any policy features or benefits, or
whether the Company will be solely responsible for any benefits or features associated with the Policy.

 Response: There are no types of guarantees
or support agreements with third parties to support any policy features or benefits. The Company will be solely responsible for any benefits or features associated with the Policy.

Comment 3.

 Please include a power of attorney that
specifically authorizes the filing of the current registration statement. At present, the registration statement incorporates by reference a power of attorney that does not cover this specific filing. See rule 483(b) under the Securities Act of
1933.

 Response: Registrants will include powers of attorney that specifically authorize the filing of the current registration statements.

 Comment 4.

Please include the date of the filing at the top of the EDGAR facing sheet.

Response: The date of the pre-effective amendment filing will be included at the top of the EDGAR facing sheet.

 Cover Page

 Comment
5.

 The second sentence of the last paragraph notes that upon cancellation, the Company refunds either the full amount paid with the application or
total Policy Value. Please explain how this is determined (e.g., the greater of amount paid or Policy Value). Please also clarify whether any charges deducted during the free look period will be added to the refund of Policy Value. In addition, if
true, please disclose in the national product that if the policy is intended to replace an existing policy, the cancellation period is extended to 60 days (as noted in the New York product).

Response: The sentence has been revised to read: Upon cancellation, you will receive a full refund of all premiums paid, including any policy fees or
other charges, less Indebtedness.

 Note that a cancellation period of 60 days is only required by the state of New York, and not by other states,
if the policy is intended to replace another policy.

 Comment 6.

Please include a definition of “Indexed Accounts” in the Key Terms. Please also include a definition for the terms “Surrender” and
“Partial Surrender,” noting that sometimes a partial surrender is also referred to as a withdrawal.

 Response: We have included the
following definitions in Key Terms:

 Indexed Account: The portion of the Policy Value that has the ability to earn interest based on a change in the value
of one or more designated indexes.

 Partial Surrender: The withdrawal of an amount of the Policy Value that is less than the full Cash Surrender Value.
Sometimes we refer to a Partial Surrender as a withdrawal.

 Full Surrender: The withdrawal of the full Cash Surrender Value and termination of the
policy.

 Comment 7.

 In the Specified Amount
definition, please consider stating in plain English, as noted on page 9, that the Specified Amount is the amount of life insurance coverage an Owner wants (i.e., the “Specified Amount” of insurance).

Response: The definition has been revised to read:

Specified Amount: An amount chosen by you we use to determine the death benefit and the Proceeds payable upon death of the last surviving Insured prior to the
youngest Insured’s Attained Insurance Age 120 Policy Anniversary. If death benefit option 1 is chosen, this is the amount of life insurance coverage you want. For death benefit option 2 and 3, this is the minimum amount of life insurance
coverage. We show the initial Specified Amount you have chosen in your policy.

 Key Information Table

Comment 8.

 The Fees and Expenses section includes a
cross reference to the Fee Tables. Please also include a cross reference to a location in the Statutory Prospectus where the fees and expenses are described in more detail (e.g., Transaction Fees and Base Policy Charges). Please note that
cross-references in the electronic versions of the summary and statutory should directly link to the location in the statutory referenced.

 Response: Revised as requested. The cross-references in the electronic versions of the summary and
statutory prospectuses will directly link to the location in the statutory prospectus referenced.

 Comment 9.

In the “Charges for Early Withdrawals” information, please include the maximum surrender charge (as a percentage of contribution/premium or amount
surrendered). Please also provide an example of the maximum surrender charge an Owner could pay (in dollars) under the Contract assuming a $100,000 investment. See Item 2, Instr. 2(a).

Can the disclosure be clarified/revised to address the maximum surrender charge based on this explanation?

Also, what examples are being referenced here?

 Response:
Our maximum surrender charges for a full surrender are not calculated as a percentage of contribution/premium or amount surrendered. The maximum surrender charge is based on the initial specified amount. For instance, if two policyholders both
purchased a $1MM policy, even if one invested $100,000 and one invested $80,000 – their surrender charges would be the same. Therefore, the examples we have provided for the maximum surrender charges are not based on the amount of money the
owner will pay but are based on the specified amount.

 The disclosure in the “Charges for Early Withdrawals” has been revised to read:

If you surrender your policy for its full Cash Surrender Value, or the policy Lapses, during the first ten years and for ten years after requesting an
increase in the Specified Amount, you will incur a Surrender Charge. The Surrender Charges are set based on various factors such as the Insureds’ Insurance Ages (or Attained Insurance Ages at the time of a requested increase in the Specified
Amount), Risk Classifications, and the number of years the policy has been in force (or for the number of years from the effective date of an increase in Specified Amount).

The maximum initial Surrender Charge rate that would be charged on any policy would be $42.828 per $1,000 of initial Specified Amount. Therefore, if a
Full Surrender occurs on a policy that was issued with a $1,000,000 initial Specified Amount, the maximum initial Surrender Charge would be $42,828 which is $42.828 times $1,000,000 divided by 1,000. This Surrender Charge for the initial
Specified Amount will remain level for the first five policy years and then decrease monthly until it is zero at the end of the tenth policy year.

 The
Surrender Charges that apply to your policy are shown under the Policy Data page of your policy.

 Comment 10.

In the “Transaction Charges” information, please specify the riders and benefits under the policy that impose a fee upon exercise.

Response: The disclosure has been revised to read: In addition to surrender charges, you may also incur charges on other transactions, such as a
premium expense charge, partial surrender charge, express mail fee, electronic fund transfer fee, and fees imposed when exercising your rights under the Overloan Protection Benefit and the Policy Split Option Rider. If you take a loan against the
policy, you will be charged a loan interest rate on any outstanding balance until the loan is paid off.

 Comment 11.

In the “Ongoing Fees and Expenses” row of the table, please specify the applicable optional benefits, as some optional benefits are subject to a
transaction charge and others are subject to annual charges. Please also include narrative disclosure regarding the ongoing fees and expenses associated with the Indexed Options. (e.g., “An investment in an Indexed Account is also
subject to an ongoing charge of 0.60%.”).

 Response: The disclosure has been revised to read: In addition to Surrender Charges and transaction
charges, an investment in the policy is subject to certain ongoing fees and expenses, including fees and expenses covering the cost of insurance under the policy and the cost of the Accounting Value Increase Rider and the Four-Year Term rider if
they are elected as optional benefits available under the policy. Such fees and expenses are set based on various factors such as the Insureds’ Risk Classifications, Issue Ages, genders and the number of years the policy is

 in force. You should review the rates, fees and charges under the Policy Data page of your policy. You will also
bear expenses on any Policy Value in the Indexed Accounts at an annual rate of 0.60% applied monthly.

 Comment 12.

In the “Not a Short-Term Investment” section, in order to be consistent with the form instruction, please lead with the second sentence, which
states, “The policy is not suitable as a short-term investment and may not be appropriate for an investor who needs ready access to cash.”

Response: Revised as requested.

 Comment 13.

When describing Risks Associated with Investment Options, please revise the disclosure consistent with the statement required by Instruction 3.(c) to Item 2 of
Form N-6.

 Response: Revised as requested.

Comment 14.

 For clarity, when describing Insurance
Company Risks, please substitute “us” with “RiverSource Life Insurance Company.”

 Response: Revised as requested.

Comment 15.

 In the “Policy Lapse” section of
the Risks table, please briefly reference the No-Lapse Guarantee. Please also consider briefly disclosing the operation of the grace period.

Response: The disclosure in the “Policy Lapse” section of the Risks table has been revised to read:

Insufficient premium payments, fees and expenses, poor investment performance, full and partial surrenders, and unpaid loans or loan interest may cause the
policy to Lapse. There is a cost associated with reinstating a Lapsed policy. Death benefits will not be paid if the policy has Lapsed. Your policy may not Lapse if the No Lapse Guarantee is in effect. Also, your policy enters a grace period before
Lapsing, allowing you additional time to pay the amount required to keep the policy in force.

 Comment 16.

Please replace the sub-heading “Investment Options” with “Investments” under the
“Restrictions” heading.

 Response: Revised as requested.

Comment 17.

 When describing “Optional
Benefits” restrictions, please identify the optional benefits in which certain restrictions and limitations apply. Please also identify which optional benefits are only available at policy issuance.

Response: The disclosure has been revised to read:

• The Four-Year Term rider (FYT), Policy Split Option Rider (PSO), and the Accounting Value Increase Rider (AVIR) are only available at
policy issuance.

 • The FYT and PSO are not available for all Insurance Ages or Risk Classifications that would be Insured under the
base policy.

 • The FYT, PSO, and AVIR have termination dates prior to the termination date of the base policy.

• The PSO, AVIR and Overloan Protection Benefit (OPB) have certain conditions that must be satisfied to exercise the benefit of these
riders.

 Comment 18.

 In the “Tax Implications” section, please clarify the second bullet point to state, “If your
policy is a modified endowment contract, you may have to pay a 10% tax penalty if you take a withdrawal before age 591⁄2.”

Response: Revised as requested.

 Overview
of the Policy

 Comment 19.

 In the
“Premiums” section, the disclosure states that the policy may lapse if you do not pay the premiums needed to maintain coverage. However, the disclosure also states that the policy includes a No-Lapse
Guarantee benefit, which, subject to certain requirements, guarantees the policy will remain in force even if the Cash Surrender Value is insufficient to pay the monthly deduction. Please explain the limits of the
No-Lapse Guarantee benefit in this section or provide a cross-reference to where this is described elsewhere in the prospectus.

Response: The following sentence has been added at the end of the second paragraph in the “Premiums” section:

See “No Lapse Guarantees” under the “Keeping the Policy in Force” section below.

Comment 20.

 In the “Allocation of Premiums,”
the disclosure references a complete list of underlying Funds “at the back of this document.” Instead, please reference “Appendix A: Funds Available Under the Contract.”

Response: The disclosure has been revised to read: A complete list of underlying Funds can be found in “Appendix A: Funds Available
Under the Contract”.

 Comment 21.

 In the
“Loans” discussion, please consider describing the purpose of loans (i.e., to access policy value without the taxes and surrender charges associated with withdrawals).

Response: The following disclosure has been added as the second sentence in the “Loans” discussion:

Generally, this allows you to access Policy Value without the taxes and surrender charges associated with a withdrawal.

Comment 22.

 The “Optional Benefits Riders”
disclosure under “Policy Features” notes the availability of riders “varies from state to state.” Please disclose these state variations or include a cross reference to where these state variations are described.

Response: We have removed the sentence, “Availability of riders varies from state to state.”

Registrant is adding an appendix to the national version of the prospectus to address policy availability by jurisdiction. Policy availability drives rider
availability. The riders referenced in this section are available with the policies approved in the jurisdictions that will be captured in the state availability appendix.

Fee Table

 Comment 23.

Consider showing the Loan Interest Spread in the “Interest Rate on Loans” row of the Transaction Fees table” or include a footnote disclosing
that the interest rate charged on a loan is offset by the minimum guaranteed rate of interest earned at the Fixed Account (i.e., 1.00%) on the loan collateral.

 Response: The following footnote has been added to “Interest Rate on Loans” section of the
“Transaction Fees” portion of the “Fee Tables”:

 The loan interest rate charged is offset by the minimum guaranteed rate of interest
of 1.00% earned on the Fixed Account that is credited on the loan collateral.

 Comment 24.

In the “Periodic Charges” table, please add the title “Base Contract Charge” (or “Base Policy Charge”). Please also consider
including the Overloan Protection Benefit and Policy Split Option Rider in the fee table and indicating there is no additional charge.

 Response:
Revised as requested.

 Comment 25.

 In the
narrative to the “Annual Portfolio Company Expenses” table, the disclosure references a complete list of underlying Funds “at the back of this document.” Instead, please reference “Appendix A: Funds Available Under the
Contract.”

 Response: Revised as requested.