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CORRESP
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CORRESP

 December 5, 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 of New York Account 8 (“Registrant”)

RiverSource Life Insurance Co. of NY (“Company”)

Post-Effective Amendment No. 12 on Form N-6

File Nos. 333-227507 / 811-05213

RiverSource Variable Universal Life 6 Insurance

Dear Mr. Cowan:

 On behalf of RiverSource Life Insurance
Co. of NY (the “Company”), we are responding to the comments of the Securities and Exchange Commission provided to us on December 1, 2023, with regard to the Registration Statement referenced above. Along with this letter, we are
filing the revised supplement, which reflects conforming edits.

 Comments and responses are outlined below.

Comment: If changes in this supplement apply only to new investors, in the introductory paragraph, change “your current variable insurance product
statutory and initial summary prospectus” to “the current variable insurance product statutory and initial summary prospectus.”

Response: Revised as requested.

 Comment: Please
clarify, under I., that the Cost of Insurance and Administrative Charges apply to policies with an application date on or after 1/13/2024 and add that all other Policy fees and charges are as stated in the Fee Table.

Response: Revised as requested.

 Comment: If all
changes are applicable to policies issued on or after 1/13/2024, the supplement should include only changes for policies issued on or after 1/13/2024 and all references to policies with application dates before 1/13/2024 removed. The supplement
should be delivered just to new investors.

 Response: Revised as requested.

 1

 Comment: Under II. Funds available under policy, all items referring to existing investors should be
removed.

 Response: Revised as requested.

Comment: Please clarify if all listed funds are available fund offerings for new policies on or after 1/13/24 or just additional ones. To avoid
confusion and for purposes of clarity as to what funds will be available after 1/13/2024, the table below should list all funds available after 1/13/2024.

Response: The table has been revised to include all funds available for policies with applications dated on or after 1/13/2024.

Comment: Please include in the supplement any changes in the KIT or Annual Portfolio Company Expenses Minimum Maximum table, if any of the fund lineup
changes affect those disclosures.

 Response: The KIT and Annual Portfolio Company Expenses Minimum and Maximum Table have been revised and added to
the supplement to reflect the fund lineup changes.

 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

 2

 

Supplement dated December XX, 2023 to Statutory Prospectus and
initial Summary Prospectus dated April 26, 2023

Product Name

Prospectus Form #/Date

RiverSource® Variable Universal Life 6 Insurance

  PRO9089_12_B01_(05/23)

 ISP9089_12_B01_(05/23)

 The information in this supplement updates and amends certain information contained in the current variable life insurance product statutory and initial summary prospectus (together, the “prospectus”). Please read it carefully and keep it with your variable life insurance product prospectus for future reference. Except as modified in this supplement, all other terms and information contained in the prospectus remain in effect and unchanged. The terms we use in this supplement have the same meaning as in the prospectus.

 I. Effective 1/13/2024, the Cost of Insurance Charge and Administrative Charge descriptions in the “Fee Table – Periodic Charges Other than Annual Fund Expenses” are deleted and replaced with the following information, for policies with application dates on or after 1/13/2024. All other policy fees and charges are as stated in the Fee Table.

  

  CHARGE

  WHEN CHARGE IS DEDUCTED

  AMOUNT DEDUCTED

  Cost of Insurance
Charge(a)

 For policies with application

 dates on or after 1/13/2024.

  Monthly.

  Monthly rate per $1,000 of Net Amount at Risk:

  Minimum: $0.005 — Female, Standard Nontobacco,

Insurance Age 0, Duration 5.

  Maximum: $57.6325 – Male, Standard Tobacco,

Insurance Age 85, Duration 28.

  Representative Insureds: $0.0125 – Female, $500,000

 Specified Amount, Super Preferred Nontobacco,

Insurance Age 40, Duration 1.

  Administrative
Charge(a)

 For policies with application

 dates on or after 1/13/2024.

  Monthly.

  Monthly Rate per $1,000 of initial Specified Amount:

  Minimum: $0.098 — Female, Standard Nontobacco,

Insurance Age 0, Duration 1.

  Maximum: $2.979 — Male, Standard Tobacco,

Insurance Age 85, Duration 1.

  Representative Insured: $0.148 Female, Super

Preferred Nontobacco, Insurance Age 40, Duration 1.

 (a) This charge varies based on individual characteristics. The charges shown in the table may not be representative of the charge you will pay. For information about the charge you would pay, contact your sales representative or RiverSource Life of NY at the address or telephone number shown on the first page of this prospectus.

 II. For policies with application dates on or after 1/13/2024, Ongoing fees and Expenses in the Key Information Table – Information You Should Consider About the Policy, is deleted and replaced in its entirety with the following:

Key Information Table

1

 Important
Information You Should Consider About the Policy 

FEES AND EXPENSES

Location in

Statutory

Prospectus

Ongoing Fees and

Expenses (annual

charges)

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 following riders if elected as optional benefits
available under the

 policy: Accounting Value Increase Rider,
Accidental Death Benefit Rider,

 Children's Insurance Rider,
Waiver of Monthly Deduction Rider, Waiver of

 Premium Rider and
the AdvanceSource Accelerated Benefit for CI if they

are elected as optional benefits available under the policy. Such fees and

 expenses are set based on various factors such as the Insured’s Risk

 Classification, Insurance Age, sex 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 associated with the Funds offered under the

policy, as shown in the following table:

  Fee Tables

 Transaction Fees

 Base Policy

 Charges

Annual Fee

Minimum

Maximum

Underlying Fund options

(Funds fees and expenses)(1)

0.25

1.26

(1) As a percentage of Fund assets.

 III. For policies with application dates on or after 1/13/2024, Total Annual Operating Expenses of the Funds in the Fee Tables section of the prospectus is deleted and replaced in its entirety with the following:

Total Annual Operating Expenses of the
Funds

 The
next table provides the minimum and maximum total operating expenses charged by the underlying Funds(1) that you may pay periodically during the time that you own the policy. A complete list of
Funds available under the policy, including their annual expenses, may be found in Appendix A: Funds Available Under the Policy.  

Total Annual Fund Expenses

Minimum(%)

Maximum(%)

(expenses deducted from the Fund assets, including management fees and other
expenses)

  0.25

1.26

(1)

Total annual Fund operating expenses are deducted from amounts that are allocated to the
Fund. They include management fees and other expenses. Other expenses may include service fees that may be used to compensate service providers, including us and our affiliates,
for administrative and contract owner services provided on
behalf of the Fund. The amount of these payments will vary by Fund and may be significant. See “The
Variable Account and the
Funds” for additional information, including potential conflicts of interest these payments may
create. For a more complete description of each Fund’s fees and expenses and important disclosure regarding payments the Fund and/or its affiliates make, please review the Fund’s prospectus and SAI.

IV. Funds available under the policy.

For policies with application dates on or after 1/13/2024, the Section in the prospectus titled
“Appendix A: Funds Available Under the Contract” is replaced with the following.

Appendix A: Funds Available Under the Contract

 The
following is a list of funds available under the contract. More information about the funds is available in the prospectuses for the
funds, which may be amended from time to time and can be found online at riversource.com/insurance. You can also request this information at no cost by calling 1-800-862-7919 or by sending an
email request to riversourceannuityservice@ampf.com.

 The current expenses and performance
information below reflects fee and expenses of the funds, but do not reflect the other fees and expenses that your contract may charge. Expenses would be higher and performance would be lower if these
other charges were included. Each fund’s past performance is not necessarily an indication of future
performance. 

2

Investment Objective

Fund and

Adviser/Sub-Adviser

Current

Expenses

Ratio

[NET]

Average Annual Total Returns

(as of
12/31/2022)

1 Year

5 Year

10 Year

Seeks long-term growth

of capital

AB VPS Large Cap Growth Portfolio (Class A)

AllianceBernstein L.P.

  0.65%

  (28.51%)

  11.54%

 15.08%

Seeks long-term capital

appreciation.

Allspring VT Small Cap Growth Fund -

Class 1

Allspring Funds Management, LLC, adviser;

Allspring Global Investments, LLC,

sub-adviser.

  0.94%

  (34.30%)

  7.35%

 10.85%

The Portfolio seeks

investment results that

correspond (before fees

and expenses) generally

to the price and yield

performance of its

underlying index, the

Alerian Midstream

Energy Select Index (the

"Index").

ALPS | Alerian Energy Infrastructure

Portfolio: Class I

ALPS Advisors, Inc.

  0.95%1

  17.84%

  3.77%

 -

Seeks long-term capital

growth. Income is a

secondary objective.

American Century VP Mid Cap Value, Class I

American Century Investment Management,

Inc.

  (1.19%)

  6.76%

 11.01%

Seeks long-term capital

growth. Income is a

secondary objective.

American Century VP Value, Class I

American Century Investment Management,

Inc.

  0.73%1

  0.54%

  7.85%

 10.59%

Seeks high total

investment return.

BlackRock Global Allocation V.I. Fund

(Class I)

BlackRock Advisors, LLC, adviser; BlackRock

(Singapore) Limited, sub-adviser.

  0.73%1

  (15.86%)

  3.50%

 5.06%

Seeks investment

results that correspond

to the total return

performance of common

stocks as represented

by the MSCI EAFE Index.

Calvert VP EAFE International Index Portfolio

- Class I

Calvert Research and Management

  0.48%1

  (14.58%)

  1.35%

 4.07%

Seeks investment

results that correspond

to the investment

performance of U.S.

common stocks, as

represented by the

NASDAQ 100 Index.

Calvert VP Nasdaq 100 Index Portfolio -

Class I

Calvert Research and Management, adviser;

Ameritas Investment Partners, Inc,

subadviser.

  0.48%1

  (32.64%)

  11.83%

 15.82%

Seeks investment

results that correspond

to the investment

performance of U.S.

common stocks, as

represented by the

Russell 2000® Index.

Calvert VP Russell 2000® Small Cap Index

Portfolio - Class I

Calvert Research and Management, adviser;

Ameritas Investment Partners, Inc,

subadviser.

 0.40%1

 (20.52%)

 3.87%

 8.57%

  3

Investment Objective

Fund and

Adviser/Sub-Adviser

Current

Expenses

Ratio

[NET]

Average Annual Total Returns

(as of
12/31/2022)

1 Year

5 Year

10 Year

Seeks to achieve a

competitive total return

through an actively

managed portfolio of

stocks, bonds and

money market

instruments which offer

income and capital

growth opportunity.

Calvert VP SRI Balanced Portfolio - Class I

Calvert Research and Management

  0.64%

  (15.41%)

  6.32%

 7.57%

Seeks maximum total

investment return

through a combination

of capital growth and

current income.

Columbia Variable Portfolio - Balanced Fund

(Class 1)

Columbia Management Investment Advisers,

LLC

  0.74%1

  (16.65%)

  5.50%

 8.10%

Seeks to provide

shareholders with total

return.

Columbia Variable Portfolio - Commodity

Strategy Fund (Class 1)

Columbia Management Investment Advisers,

LLC

  0.75%

  19.09%

  7.70%

 -

Seeks total return,

consisting of long-term

capital appreciation and

current income.

Columbia Variable Portfolio - Contrarian Core

Fund (Class 1)

Columbia Management Investment Advisers,

LLC

  0.68%1

  (18.65%)

  8.44%

 12.12%

Seeks to provide

shareholders with

capital appreciation.

Columbia Variable Portfolio - Disciplined

Core Fund (Class 1)

Columbia Management Investment Advisers,

LLC

  0.67%

  (18.72%)

  8.17%

 11.98%

Seeks to provide

shareholders with a high

level of current income

and, as a secondary

objective, steady growth

of capital.

Columbia Variable Portfolio - Dividend

Opportunity Fund (Class 1)

Columbia Management Investment Advisers,

LLC

  0.73%1

  (1.11%)

  8.10%

 10.06%

Non-diversified fund that

seeks to provide

shareholders with high

total return through

current income and,

secondarily, through

capital appreciation.

Columbia Variable Portfolio - Emerging

Markets Bond Fund (Class 1)

Columbia Management Investment Advisers,

LLC

  0.75%

  (16.03%)

  (1.63%)

 0.67%

Seeks to provide

shareholders with

long-term capital growth.

Columbia Variable Portfolio - Emerging

Markets Fund (Class 1)

Columbia Management Investment Advisers,

LLC

  1.09%1

  (32.90%)

  (3.03%)

 1.55%

Seeks to provide

shareholders with high

total return through

income and growth of

capital.

Columbia Variable Portfolio - Global Strategic

Income Fund (Class 1)

Columbia Management Investment Advisers,

LLC

 (13.49%)

 (0.67%)

 (1.19%)

  4

Investment Objective

Fund and

Adviser/Sub-Adviser

Current

Expenses

Ratio

[NET]

Average Annual Total Returns

(as of
12/31/2022)

1 Year

5 Year

10 Year

Seeks to provide

shareholders with

maximum current

income consistent with

liquidity and stability of

principal.

Columbia Variable Portfolio - Government

Money Market Fund (Class 1)

Columbia Management Investment Advisers,

LLC

  0.34%1

  1.22%

  0.99%

 0.54%

Seeks to provide

shareholders with high

current income as its

primary objective and,

as its secondary

objective, capital

growth.

Columbia Variable Portfolio - High Yield Bond

Fund (Class 1)

Columbia Management Investment Advisers,

LLC

  0.64%1

  (10.54%)

  2.42%

 3.89%

Seeks to provide

shareholders with a high

total return through

current income and

capital appreciation.

Columbia Variable Portfolio - Income

Opportunities Fund (Class 1)

Columbia Management Investment Advisers,

LLC

  0.64%1

  (10.01%)

  2.22%

 3.63%

Seeks to provide

shareholders with a high

level of current income

while attempting to

conserve the value of

the investment for the

longest period of time.

Columbia Variable Portfolio - Intermediate

Bond Fund (Class 1)

Columbia Management Investment Advisers,

LLC

  0.50%

  (17.06%)

  0.43%

 1.39%

Seeks to provide

shareholders with

long-term capital growth.

Columbia Variable Portfolio - Large Cap

Growth Fund (Class 1)

Columbia Management Investment Advisers,

LLC

  0.70%1

  (31.38%)

  9.21%

 12.60%

Seeks to provide

shareholders with

long-term capital

appreciation.

Columbia Variable Portfolio - Large Cap Index

Fund (Class 1)

Columbia Management Investment Advisers,

LLC

  0.25%

  (18.34%)

  9.12%

 12.22%

Seeks to provide

shareholders with a

level of current income

consi