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CORRESP
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CORRESP

 Feb. 17, 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

RiverSource Variable Account 10

Post-Effective Amendment No. 3 on Form N-4

File Nos. 333-230376/811-07355

RiverSource RAVA 5 Advantage® Variable Annuity

(offered for contract applications signed on or after April 29, 2019)

Dear Mr. Cowan:

 This letter is in response to the
Staff’s comments we received on Feb. 8, 2021 for the above-referenced Registration Statement which we filed on or about Jan. 13, 2021. Comments and responses are outlined below.

General:

 Comment:

We noted from the cover letter that there are changes to the number of transfers allowed each contract year for SecureSource 5 and SecureSource 5 Plus. We didn’t see changes to the number of transfers allowed.

 Response:

We confirm that the number of transfers allowed each contract year for SecureSource 5 and SecureSource 5 Plus did not change.

Rate Sheet Prospectus Supplement

Comment: The Required Allocation percentages for the Investment Path 2 groups for the SecureSource Tempo optional benefit riders should
not be included in the rate sheet supplement.

 Response: We note that there is industry precedent to change allocation percentages using a rate
sheet supplement. The inclusion allows a contract owner to have all applicable rider values in one location rather than having to refer to an additional supplement.

Comment: Please delete the following sentence from the second paragraph in bold, as it is not necessary:

We may periodically issue a new Rate Sheet Prospectus Supplement that may reflect different values than the previous Rate Sheet Prospectus
Supplement.

 Response: Deleted.

 Comment: There are just too many terms that are changing in this RSS and for too many different riders.
Originally, RSS were just for rates that could change frequently, please consider whether some of these terms can be in the prospectus, rather than in these RSS. We note the RSS sheet did not change during the entire year. I also don’t think
investment restriction should in RSS.

 Response: As noted above, all terms should remain as the part of the Rate Sheet Supplement. All values
included in the Rate Sheet Supplement were changed two times between May 2019 and March 2020. We expect to make changes to the values, including the investment options and restrictions, periodically. The frequency of future changes will depend in
part on market conditions

 Comment: Change the table heading “Rider fees” to the “Current Rider Fees”.

Response: Revised as requested.

 Comment: Change
the table heading “Lifetime Payment Percentage” to the “Lifetime Payment Percentage and Income Bonus percentage”.

 Response:
Revised as requested.

 Prospectus:

Cover Page

 Comment: Revise the third
paragraph and add clarification that for the SecureSource living benefit riders from page 124 investor may be paying for guarantee that company make never to pay:

You will begin paying the rider charge as of the rider effective date, even if you do not begin taking withdrawals for many years. It is possible that your
contract performance, fees and charges, and withdrawal pattern may be such that your contract value will not be depleted in your lifetime and you will not receive any monetary value under the rider.

Response: Revised as requested.

 Expense
Summary - Examples

 Comment: It appears SecureSource Core Plus (2.75%) and Enhanced Legacy (1.75%) are the most most
expensive - Is this combination of riders not possible?

 Also, it needs to be the most expensive ever offered under this contract, not just the most
expensive of currently offered benefits. Please confirm.

 Response: SecureSource Core Plus may not be purchased with the Enhanced
Legacy.

 The most expensive combination is the election of the SecureSource Core Plus (2.75%) and SecureSource Legacy (0.40%) and this
combination will be shown in the Maximum Expenses.

 The Guarantee period Accounts (GPAs)

Comment: Does this prospectus get delivered with this contract for investors who can elect into this option? It should.

Response: Registrant confirms that the prospectuses get delivered to investors investing in the Guarantee Period Accounts (GPAs).

Charges

 Comment: In the
“Mortality and Expense Risk Fee” section make clear that M&E fees listed are the current charges.

 Response: The M&E Fees will
not change while the contract is in force and the statement that we cannot increase these fees in included in the disclosure.

 Comment: In the
Optional Living Benefit charges” section for all applicable riders, please make clear that the current fee is disclosed in the rate sheet supplement.

Response: The second sentence for all applicable riders is revised to read:

The current annual rider fees applicable to the contract issued while this prospectus is in effect are shown in the Rate Sheet Prospectus
Supplement.

 Optional Living Benefits – comments applicable to all riders that have same disclosure

SecureSource Series Rider terms – Key Terms

Comment: In the Current Annual Payment term disclosure, make this plain English: e.g. and is the sum of the minimum annual lifetime payment
(specify what that is — don’t see that definition until much later) plus any Income Bonus. Also, define Income Bonus here.

 Response: The
terms disclosures are revised and a new term - Income Bonus is added.

 Current Annual Payment: the benefit available for withdrawal each contract
year after the covered person (Joint Life: the younger Covered Spouse) has reached the youngest age in the first Age Band. For SecureSource 4, SecureSource 4 Plus, SecureSource 5, SecureSource 5 Plus and SecureSource
Tempo, the Current Annual Payment can vary each contract year and is equal to the minimum annual plus an Income Bonus, when eligible.

 Excess
Withdrawal: any withdrawal taken before the Current Annual Payment is established, or any withdrawal that is greater than the Remaining Annual Payment. Any excess withdrawal request will not be considered in good order until we receive a signed
Benefit Impact Acknowledgement form showing the projected effect of the surrender on the rider benefits or a verbal acknowledgement that you understand and accept the impacts that have been explained to you.

Income Bonus: for SecureSource 4, SecureSource 4 Plus, SecureSource 5, SecureSource 5 Plus and SecureSource Tempo, a potential increase
to the Current Annual Payment. It is calculated by multiplying the Benefit Base by the Income Bonus Percentage.

 Comment: In the Income Bonus Percentage term, state that Minimum Lifetime Percentage is specified in the
Rate Sheet Supplement.

 Response: The last sentence in the term description is revised to read:

Income Bonus Percentage: for SecureSource 4, SecureSource 4 Plus, SecureSource 5, SecureSource 5 Plus and SecureSource Tempo, the Income Bonus
Percentage may be added to the Minimum Lifetime Payment Percentage as described in the “Lifetime Payment Percentage” provision below. The Income Bonus Percentage is not available under SecureSource Core, SecureSource Core Plus and
ecureSource Core Plus 2 riders. The Income Bonus Percentage and Minimum Lifetime Payment Percentages are shown in the Rate Sheet Prospectus Supplement.

Comment: In the Lifetime Payment Percentage term, in the last sentence, change “The Lifetime Payment Percentage” to the “Minimum
Lifetime Payment Percentage”, if true.

 Response: The Lifetime Payment Percentage term is revised to read:

Lifetime Payment Percentage: used to calculate your Current Annual Payment. For SecureSource 4, SecureSource 4 Plus, SecureSource 5, SecureSource 5
Plus and SecureSource Tempo, is the Minimum Lifetime Payment plus the Income Bonus Percentage, when eligible. The percentage used can vary as described in the Lifetime Payment Percentage provision below. The Lifetime Payment Percentage, Minimum
Lifetime Payment Percentages, and Income Bonus are shown in the Rate Sheet Prospectus Supplement.

 The following new term is added:

Minimum Annual Lifetime Payment: for SecureSource 4, SecureSource 4 Plus, SecureSource 5, SecureSource 5 Plus and SecureSource Tempo, the
guaranteed lifetime benefit amount available for Withdrawal each contract year. It is calculated by multiplying the Benefit Base by the Minimum Lifetime Payment Percentage.

SecureSource Tempo rider

 Comment:
The description of the rider and how it operates is so dense and hard to follow. Please revise in plain English.

 Response: The description of
the rider is revised and replaced with the following:

 The SecureSource Tempo rider is an optional benefit that you can elect at
time of application for an additional charge. It may not be purchased with any other optional living benefit and certain death benefit riders (ROPP rider, MAV rider or Enhanced Legacy benefit rider). This benefit is intended to provide a
specified withdrawal amount annually for life, even if your contract value is zero, subject to the terms and provisions described in this section. Additionally, this benefit offers a Returns-linked Credit feature and a
step-up feature to lock in contract anniversary gains to increase the Benefit Base and the lifetime payment.

 If the contract value is reduced to zero due to market performance, fees or charges, or a
withdrawal that does not exceed the amount available under the rider, then you will receive lifetime payments made by us as described in the “Other provisions - Rules for Surrender.” However, the contract and rider will terminate if the
contract value goes to zero due to an excess withdrawal. If you die before the contract value is depleted, you will not receive any monetary value from the rider.

Comment: In the last sentence in the first paragraph, should the “Remaining Annual Payment” be referred as the “Current Annual
Payment”?

 Response: Please see revised paragraph above.

Comment: Clarify here and throughout where this or similar disclosure is used that if contract value is reduced to zero because of withdrawals before
the Current Annual Amount is established, then the rider terminates. Also, investors should be warned against making withdrawals before the Current Annual Payment is established.

For clarity is it the last withdrawal that result in contract value going to zero or are all prior withdrawals factors into this? Clarify.

Response: The Excess Withdrawal term definition is updated to state that we will use a Benefit Impact Acknowledgement form and show
client the impact of taking an excess withdrawal (including withdrawals before the Current Annual Payment is established) before processing their request. The following revision is made to the disclosure:

The SecureSource Tempo rider may be not appropriate for you if:

•

 you anticipate the need for withdrawals before the lifetime benefit is established or withdrawals that exceed the
amount available under the rider (i.e. excess withdrawals); or

•

 you want to invest in funds other than the approved investment options. Certain approved investment
options may only be available within an allocation plan, subject to requirements and limitations. For a list of currently approved investment options and allocation plans, see “Investment Allocation Restrictions for Certain
Benefit Riders”.

 Comment: It looks like the word is missing in the following sentence:

Each contract year, whether or not the Income Bonus Percentage is included in the Lifetime Payment Percentage is determined when the first he
remainder of that contract year (see “Lifetime Payment Percentage” below).

 Response: The sentence is revised to read:

On the day of your first withdrawal each contract year, we determine if the Income Bonus is available for that contract year (see
“Lifetime Payment Percentage” below).

 Comment: Revise the Rate Sheet Prospectus Supplement paragraph to: add the reference to the
current rider charges, delete reference to the required allocation percentages and maximum fund allocations, either specify the actual terms that can change or say “ the terms contained in a RSS for the next effective period, we will file a new
RSS. Also, it looks like the word is missing in the third to last sentence.

 Response: The Rate Sheet Prospectus Supplement paragraph is revised to read (changes underlined):

RATE SHEET PROSPECTUS SUPPLEMENT

 The current rider
charges and the current rates for the Lifetime Payment Percentages, Income Bonus Percentage, Credit Period, Maximum Credit percentage, Maximum Carryover percentage and Credit Multiplier applicable to your contract are disclosed in
the Rate Sheet Supplement attached to this prospectus. The required allocation percentages and maximum fund allocations for the Investment Path 2 groups are disclosed in the Rate Sheet Supplement attached to this prospectus. These terms can
only change as provided in this prospectus (see “Lifetime Payment Percentage”, “Income Bonus percentage”, “Returns-linked Credit”, “Credit Carryover”, below.) We may change these terms for new purchasers, upon
7 calendar days prior notice. At least 7 calendar days before we change the terms contained in a Rate Sheet Supplement for the next effective period, we will file a new Rate Sheet Supplement. All historical Rate Sheet
Supplements are reflected in Appendix

G. All Rate Sheet Prospectus Supplements, including the Rate Sheet Supplement applicable to you, have been filed with the Securities and Exchange Commission (the “SEC”) and are also available on the Edgar
system at www.sec.gov (File No. 333 – 230376).

 Comment: In the “Current Annual Payment Description – Current Annual
Payment”,

 last sentence, clarify if the “Lifetime Payment Percentage” is the right term or it should be the “Remaining Annual
Payment”?

 Response: The sentence is revised to read:

When the first withdrawal is taken in each contract year, we will determine if the Income Bonus Percentage will be included in the Lifetime
Payment Percentage for the remainder of that contract year.

 Comment: In the “Rules for Surrender”, Clarify here and throughout
where this or similar disclosure is used that if contract value is reduced to zero because of withdrawals before the Current Annual Amount is established, then the rider terminates. Also, investors should be warned against making withdrawals before
the Current Annual Payment is established.

 For clarity is it the last withdrawal that result in contract value going to zero or are all prior withdrawals
factors into this? Clarify

 Response: The third bullet/scenario in this section states that “If the Current Annual Payment is not established
and if the contract value is reduced to zero as a result of a withdrawal taken before the Current Annual Payment is established, the rider and the contract will terminate.”

We have also changed the definition of an excess withdrawal to disclose that the client must acknowledge the impact of an excess withdrawal (including taking a
withdrawal before the Current Annual Payment is established) before we will process the request.

 Comment: In the “At Death – Joint
Life”, clarify what does the sentence, “If spousal continuation is not available, the rider terminates.”, mean.

 Response:
The spousal continuation is explained in greater details in the “If You Die Before the Annuitization Start Date” section and the cross reference to this section is added.

 In addition, we have added clarification to the “If You Die Before the Annuitization Start Date”
section, as shown below (changes underlined):

 Nonqualified annuities

Spousal continuation: If your spouse is sole primary beneficiary and you die before the annuitization start date, your spouse may
keep the contract as owner with the contract value equal to the death benefit that would otherwise have been paid (with