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CORRESP
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CORRESP

 November 20, 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:
 Post-Effective Amendment No. 14 to the Registration Statement on Form
N-6

 RiverSource Life Insurance Company (“Company”)

 RiverSource Variable Life Separate Account (“Registrant”)

 File Nos. 333-227506 /
811-04298

 RiverSource Variable Universal Life 6 Insurance v3

Dear Mr. Cowan:

 On behalf of RiverSource
Life Insurance Company (the “Company”), we are responding to the comments of the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) provided to us November 10, 2023, with regard to the
Post-Effective Amendment No. 14 to the Company’s registration statement on Form N-6 for RiverSource Variable Universal Life 6 Insurance, an individual flexible premium variable life insurance policy.
Along with this letter, we are filing a revised statutory prospectus which reflects conforming edits.

 Comments and responses are outlined below.

General

 Comment: Comments should also be applied
to the ISP, where applicable.

 Response: Noted.

Comment: ISP “Key Information Table” heading should conform to “Important Information You Should Consider About the Policy” title.

 Response: Revised as requested.

 Key Terms

 Comment: The Indexed Account definition should be revised for clarity.

Response: The Indexed Account definition has been revised as follows:

 Indexed Account: The portion of the Policy Value that has the ability to earn interest on a
segment maturity date based on a change in the value of one or more designated indexes. Each Indexed Account includes a corresponding Interim Account and one or more Segments.

Comment: Consider added disclosure elsewhere in the prospectus: state that the index interest rate credited to the segment of an indexed account over
an index interest period will always be greater than or equal to the segment floor which is either zero or one percent depending on which point to point index account is selected.

Response: Disclosure appears elsewhere in the Indexed Accounts section.

Comment: Disclose that even with an index interest rate credited guaranteed to be greater than or equal to the segment floor, the policy value in the
indexed account may decrease due to the indexed account charge and an investor could lose money.

 Response: Revised as requested.

Comment: The definition of Indexed Loan Base Account is confusing and needs revisions to explain in plain English what happens to money in this
account. We did not see such disclosure elsewhere. Please include a separate section elsewhere in the prospectus describing the Indexed Loan Base Account and explaining its operation. This section should state that it is part of the General Account,
if true, and whether the account earns interest and at what rate.

 Response: Revised as follows:

Indexed Loan Base Account: The Indexed Loan Base Account will be the S&P 500 1 Year Point-to-Point Indexed Account. Policy value is transferred/reallocated from the Fixed Account, Subaccounts and/or other Indexed Accounts to ensure that the value in the Indexed Accounts is greater than
Indebtedness when an indexed loan is in effect. As a result, this account receives any applicable transfer amounts due to the following when an indexed loan is in effect:

1.
 Indexed loan reallocation of Segment maturity values.

2.
 Indexed loan transfer of Policy Value at Policy Anniversary.

Policy value transfer/reallocated for this reason will be applied to the corresponding Interim Account, moved into Segments
and will receive indexed interest on the Segment Maturity Date as any other transfer to the Indexed Account.

 Comment: At a minimum, the
definitions for eligible account and ineligible accounts should be revised for plain English. They appear to be terms created to explain the operation of the indexed loan base account. Consider eliminating the terms and revising the disclosure of
the indexed loans to describe how the company ensures enough policy value remains in the indexed accounts to serve as collateral for an indexed loan using existing terminology, i.e. fixed accounts,

subaccounts and indexed accounts. Further, the relation between an eligible and ineligible account is not clear. Alternatively, if left the way it is, the reference to certain subaccounts in the
Eligible Accounts definition should eliminate certain and specify the accounts.

 Response: Definitions have been revised as follows:

Eligible Accounts: The following Indexed Accounts are the Eligible Accounts:

•

 S&P 500 1-Year Point-to-Point

•

 S&P 500 1-Year Point-to-Point Spread/No Cap

 Policy Value in the Eligible Accounts is used to
determine if, upon any Segment Maturity Date, changes to Segment maturity reallocations are needed due to outstanding indexed loan Indebtedness.

Ineligible Accounts: The Subaccounts, the Fixed Account and/or Indexed Accounts that are not designated as Eligible Accounts.

Comment: Policy Value – Does the policy value also include the value of the indexed loan base account?

Response: The Indexed Loan Base Account is not a separate, new account, but rather it is the S&P 500 1-Year
Point-to-Point indexed account as clarified in the revised Indexed Loan Base Account definition. The Policy Value definition already includes the value of the Indexed
Accounts.

 Comment: Pro Rata Basis – Confirm that the definition is accurate given the changes. Define SDCA upon first use. As part of
disclosure elsewhere, the company as part of its automated dollar cost averaging program “may also make available. a SDCA. If the program is not currently offered delete references here and throughout the prospectus. Regarding the DCA account
shown in the optional benefit table: Does pro rata basis impact DCA? Add disclosure, if appropriate.

 Response: Confirmed that the definition is
accurate. Revised so as to not use the acronym for the first occurrence. The SDCA is currently being offered so the reference will remain. A regular DCA that uses an account chosen by the policy holder does not impact the definition of Pro Rata
Basis.

 Comment: Surrender Charge – Should this also state at time of partial surrender?

Response: – This is specifically talking about the charge upon full surrender or lapse so we have added “full” to the definition.

Key Information Table

 Comment: Transaction
Charges – “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.” Should this be described as an ongoing expense rather than a transaction
charge?

 Response: Revised as requested.

 Comment: Restrictions/Investments – Include the reservation of the right to add remove
or change one or more indexed account options. Also, state that the company may substitute a comparable index if an index is discontinued, substantially changed or the company determines that an index should no longer be used.

Response: Revised as requested.

 Comment: In the
Restrictions – Investments table, please briefly disclose the Transfer restriction policy . Provide appropriate cross-references. Please also disclose this in the Summary of Principal Risks of Investing in the Policy and in the Policy Loan
sections of the prospectus.

 Response: Revised as requested.

Comment: Please also state that an investor may only transfer amounts from an Indexed Account Option at the end of its term. Provide appropriate
cross-references. Please also disclose this in the Overview and the Summary of Principal Risks of Investing in the Policy sections of the prospectus.

Response: Revised as requested.

 Comment: If
true, please disclose in the Restrictions – Optional Benefits discussion that a change in the Specified Amount, a change in the death benefit option, the addition, deletion, or change of any riders, and/or a change in the insured’s rate
class may impact the Policy’s No-Lapse Feature and may require the payment of additional premiums to maintain the Feature’s guarantee. Please add corresponding disclosure to the Summary of Principal
Risks of Investing in the Policy and to the discussion of the No-Lapse Feature in the prospectus.

Response: Revised as requested.

 KIT Optional
Benefits

 Comment: Please specify briefly any restrictions applicable to these optional benefits. You should include what the restrictions are
rather than state “certain conditions must be satisfied.”

 Response: Revised as requested.

Comment: Loans (both fixed and indexed) should be disclosed along with a brief description of restrictions. Consider where to add and whether optional
benefits appropriate.

 Response: Revised as requested.

Premiums

 Comment: Discuss the grace period here.

 Response: Revised as requested.

 Allocation of Premiums

Comment: Please list the indexed accounts available under the policy. This could be placed in a separate appendix with a cross-reference.

Response: Revised as requested.

 Policy Features
– Accessing Your Money

 Comment: Address accessing your money from an indexed account option prior to the segment maturity date, including
whether the company will credit any index interest.

 Response: Revised as requested.

Policy Features – Death Benefit Options

Comment: Please clarify the percentage of the policy value in prong b of each death benefit option (for example, a percentage equal to the minimum
necessary for the policy to qualify as life insurance under Internal revenue code section 7702).

 Response: Revised as requested.

Comment: Loans - Add a cross reference to the applicable tax section.

Response: Revised as requested.

 Comment:
“Taking a loan may have adverse tax consequences, will reduce the Proceeds payable upon death of the Insured, and will increase your risk of Lapse.: – Please add:

•

 “You may need to make additional premium payments or loan repayments to maintain the no lapse feature.”

•

 “You may repay all or part of a loan at any time.”

Response: Revised as requested.

 Comment:
Fixed loans – Retain the following disclosure: “We charge interest on your loan.”

 Response: Revised as requested.

Comment: Please add disclosure to clarify whether the amount in the loan collateral account from the fixed loan also earns interest.

Response: Revised as requested.

 Fee
Tables/Transaction Fees/Interest Rate on Payments under Accelerated Benefit Rider for Terminal Illness (ABRTI)

 Comment: Please include the maximum Guaranteed Fixed Loan Interest Rate in addition to the current rate
and clarify whether the current rate is 1.25 or 1 % for policy years 11+.

 Response: The maximum rate is what was listed and we have updated
for clarity.

 Principal Risks of Investing in the Policy

Comment: Add the Risk associated with withdrawing amounts from an indexed account prior to the segment maturity date end of the term due to a loan or
surrender (i.e., if true, the company will not credit any index credits).

 Response: Revised based upon an earlier comment.

Comment: Add a risk factor for Policy loan risk generally, including fixed loans.

Response: Revised as requested.

 Indexed Loan Risk.

 Comment: “Although the Policy Value backing an indexed loan remains in the Indexed Accounts, there is no guarantee the indexed interest
credited on that Policy Value will be greater than the indexed loan interest charged.”

 Add “and could be less.”

Add: “Likewise, there is no guarantee that the segment growth cap offered will be greater than the indexed loan interest charged.”

Add other risks that have been noted, e.g. transfer restrictions.

Response: Revised as requested. Please note an indexed loan will not trigger a transfer restriction period because Policy Value remains in the indexed
accounts when an indexed loan is taken.

 Transfers Among the Fixed Account, Indexed Accounts and Subaccounts

Comment: “At the end of the Period of Coverage, the portion of the Policy Value will remain in the Fixed Account until written request is made to
transfer to any Subaccounts or Indexed Accounts.”

 Please define Period of Coverage here.

Response: Revised to include a definition.

 Transfers
Due to Loans

 Comment: “If, on any Indexed Account Segment Maturity Date, the amount of Indebtedness exceeds the Policy Value in the
Eligible Accounts, we reserve the right to transfer a portion of the Segment maturity value due to be reallocated to the Ineligible Account(s) to the Indexed Loan Base Account.”

 Reconcile this disclosure that states the company will reallocate—(see in the section indexed loans).
Otherwise, if it is a reservation of right and the company does not exercise this right what is the default option. Please clarify.

 Response:
Clarified as requested.

 Special Dollar-Cost Averaging

Comment: “The company, as part of its automated dollar-cost averaging program, may also make available a Special Dollar-Cost Averaging
(“SDCA”) arrangement.”

 Other disclosure suggests the SDCA arrangement is currently offered. Reconcile with other disclosure.

Response: Revised for clarity. The SDCA arrangement is available.

The Fixed Account

 Comment: “Also, if fees
and charges under the policy are deducted from the Fixed Account, you could lose more than the premiums you’ve paid into the Fixed Account. For further discussion see “Order of Deductions from Policy Value.”

Loan interest should also be mentioned here.

 Response:
Revised as requested.

 The Loan Collateral Account

Comment: For clarity, please also disclose that when you take an indexed loan no amount equal to the value of the loan is transferred to the loan
collateral account. The loan amount stays in the indexed account and, as a result, no interest is credited for loan amounts taken on an indexed loan. Suggested sentence: This is the same for loan interest accrued and not paid. Address when unpaid
accrued loan interest get deducted.

 Response: Revised as requested.

Comment: “When you take a fixed loan, or any fixed loan interest accrued is not paid when it becomes due, an amount equal to the value of the loan
or loan interest will be transferred from the Fixed Account (including the value of the Fixed Account that is part of an SDCA arrangement), Subaccounts, and/or Indexed Accounts to the Loan Collateral Account as loan collateral.” – Validate
whether the parenthetical “including the value of the Fixed Account that is part of an SDCA arrangement” is accurate.

 Response:
Validated for accuracy.

 Comment: Please clarify the circumstances as to whether amounts are transferred to the Loan Collateral
Account

 Response: Revised for clarity.

 The
Indexed Accounts

 Comment: This section should also include a chart with the indexed account options with corresponding minimum and maximum
values.

 Response: A Table of Available Indexed Accounts with corresponding values has been added to this section.

Comment: When describing the Indexed Loan Account in later prospectus disclosure, please make clear which S&P 500 Index is referenced in the index
interest calculation (i.e., the Price Return Index); explain how interest is calculated; reconcile how loan interest is charged at the end of a Policy year with how interest is credited at the end of a segment’s maturity, which may be
two different dates; explain how index interest is credited if a loan repayment is made prior to segment maturity; and clarify that the Policy will enter a Transfer Restriction Period and what that means/entails.

Response: Addressed in later prospectus disclosure in the Policy Loans section.

Comment: “The actual Indexed Interest Rates credited to the Segments of an Indexed Account will be based on various factors, including:

1)
 The Index Growth Rate which is the return of the underlying index (currently the S&P 500 Index for all
indexed accounts) over the Indexed Interest Period.”

 In