SEC Company Response from RIVERSOURCE VARIABLE ACCOUNT 10 (CIK 0001000191) — Nov 18, 2021
RIVERSOURCE VARIABLE ACCOUNT 10 (CIK 0001000191)
Date: Nov. 18, 2021 · CIK: 0001000191 · Accession: 0001193125-21-333576
AI Filing Summary & Sentiment
File numbers found in text: 333-230376, 811-07355
Letter
Division of Investment Management Securities and Exchange Commission Post-Effective Amendment #7 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. Oh:
This letter, which we have filed as Correspondence, responds to the comments we received on Oct. 18, 2021, with regard to the above-referenced Registration Statement which we filed on or about Sept. 3, 2021.
Comments and responses are outlined below.
Filing Cover Page
COMMENT: Please provide the 33 Act Number to the cover page.
RESPONSE: The 33 Act number has been added to the filing cover page.
PROSPECTUS
General
COMMENT: Any comments made with respect to one specific part of the registration statement should result in disclosure changes to any other section of the registration statement that addresses the same topic. Disclosure changes noted for the registration statement should be reflected in the related Initial Summary Prospectus and Updating Summary Prospectus, as appropriate.
RESPONSE: We will follow that approach.
Prospectus Cover Page
a. COMMENT: Fill out the date of the prospectus.
RESPONSE: The effective date of the prospectus will be added in the subsequent Post-Effective Amendments.
b. COMMENT: Add the statement required by the Rule 481(b)(1) to the cover page.
P a g e 1 | 19
RESPONSE: The following statement is added to the cover page of the prospectus:
The Securities and Exchange Commission has not approved or disapproved these securities or determined if this prospectus is accurate or complete. Any representation to the contrary is a criminal offense.
c. COMMENT: If this is not a combination prospectus filed on the Form S-3, delete the “RiverSource Account MGA” as part of the Registrant’s name.
RESPONSE: Revised as requested.
d. COMMENT: In the first paragraph, use consistent name for the product as “Individual Flexible Premium Deferred Combination fixed/variable annuity”.
e. RESPONSE: Revised as requested.
f. COMMENT: Please add a distribution channel variation to the last sentence in the first paragraph
RESPONSE: The first sentence in the first paragraph is revised to read (revision underlined):
All material terms and conditions of the contract, including material state variations and distribution channels, are described in this prospectus.
Key Terms
a. COMMENT: Revise key term describing the “Funds” to clearly define the funds relative to the definition of subaccounts and variable account.
RESPONSE: The key term describing the Funds is revised and an additional key term for the Subaccount is added:
Funds: Investment options under your contract, each with a different investment objective. Each of the Subaccounts of the Variable Account invests in a specific one of these underlying funds.
Subaccount: Each Subaccount is a separate investment division of the Variable Account and invests in a particular Fund.
b. COMMENT: Revise the key term “Variable Account” and make sure that it is the same as the RiverSource Variable Account 10.
RESPONSE: The key term is revised to read:
Variable Account: RiverSource Variable Account 10 consisting of Subaccounts, each of which invests in a particular Fund. The value of your investment in each Subaccount changes with the performance of the particular Fund.
P a g e 2 | 19
Key Information Table
A. Fees and Expenses - Ongoing Fees and Expenses
a. COMMENT: The table showing ongoing Fees and Expenses refers to the “Underlying Fund options”. Please be consistent throughout the prospectus and use the consistent terminology when referring to the underlying funds.
RESPONSE: We have addressed this comment by revising the definition of Funds and Variable Account and adding a definition for Subaccounts.
b. COMMENT: Please confirm that Min/Max reflect contract administrative charge.
RESPONSE: Min/Max percentages in the table do not reflect the contract administrative charge fee. The footnote (1) has been revised to read (changes underlined):
(1) As a percentage of average daily contract value in the variable account. The charge shown does not include the contract administrative charge in the amount of $50 for contracts with contract value less than $50,000. This charge is waived for contracts with contract value of $50,000 or more.
c. COMMENT: The footnote (1), refers to the “percentage of average daily subaccount value”. Since the percentage reflects average daily value for all subaccounts that are part of the variable account, revise to reflect this. For example, change to “percentage of average daily variable account value”.
RESPONSE: The footnote is revised as shown under (b) above.
d. COMMENT: Make sure that actual values in Min/Max depends on the rider selected and accurately describes the values for the optional benefit selected.
RESPONSE: Confirmed.
e. COMMENT: In the table showing the lowest and highest cost, revise the assumption terms to add a bullet point with “No sales charge”, per Form N-4, Item 2 (ii)(B).
RESPONSE: The following bullet point is added:
•
No sales charge
P a g e 3 | 19
B. Risks
Risks Associated with Investment Options
COMMENT: Revise the second bullet point to reflect that each investment option (including any fixed account investment option) will have its own unique risks, per Form N-4, Item 2. Instructions (3)(C).
RESPONSE: The second bullet point is revised to read:
•
Each investment option (including under any fixed account investment options) has its own unique risks.
Investments
a. COMMENT: Change the title of the section to “Investments”, per Form N-4, Item 2.
RESPONSE: Revised as requested.
b. COMMENT: Revise the statement in the last bullet point to reflect consistent naming for the funds.
RESPONSE: Revised to read:
We reserve the right to add, remove or substitute funds as investment options. We also reserve the right, upon notification to you, to close or restrict any funds.
Optional Benefits
COMMENT: Please break the first bullet into more bullet points to easier follow the restrictions.
RESPONSE: The optional benefits restrictions are revised as follows:
•
Certain optional benefits limit or restrict the investment options you may select under the Contract. If you later decide you do not want to invest in those approved investment options, you must request a full surrender.
•
Certain optional benefits may limit subsequent purchase payments.
•
Withdrawals in excess of the amount allowed under certain optional benefits may substantially reduce the benefit or even terminate the benefit.
•
We may stop offering an optional benefit at any time for new sales.
C. Taxes
a. COMMENT: Revise first bullet point to specify that the tax implications are for the investment in and purchase payments received under the contract, per Form N-4 Item 2 Instructions (5).
RESPONSE: Revised to read:
•
Consult with a tax advisor to determine the tax implications of an investment in and purchase payments received under this Contract.
b. COMMENT: In the second bullet point, please clarify that there is no additional tax benefits for the investor if the contract is purchased through the tax-qualified plan or IRA, per Form N-4, Item 2 Instructions (5).
P a g e 4 | 19
RESPONSE: Revised to read:
•
If you purchase the Contract through a tax-qualified plan or individual retirement account, you do not get any additional tax benefit.
D. Conflicts of Interest
COMMENT: Under “Investment Professional Compensation”, replace the term “additional compensation” with the term “financial incentive”.
RESPONSE: Revised as requested.
Overview of the Contract
a. COMMENT: In the Accumulation Phase paragraph, specify that the DCA Account is the Special DCA Fixed Account.
RESPONSE: Revised as requested.
b. COMMENT: Prominently disclose that additional information about each fund is provided in an appendix to the prospectus, per Form N-4 Item 3 (b), Instructions (1).
RESPONSE: The disclosure is bolded and revised to read:
A list of funds and additional information regarding each fund in which you can invest is provided in Appendix A — Funds Available Under the Contract.
c. COMMENT: Provide brief description of the GPA s and MVA with a cross-reference to the GPA prospectus filed on Form S-3.
d. RESPONSE: The following disclosure is added:
The GPAs have guaranteed interest rates for guarantee periods we declare when you allocate purchase payments or transfer contract value to them. A positive or negative MVA is assessed if any portion of a Guarantee Period Account is surrendered or transferred more than thirty days before the end of its guarantee period. A prospectus containing more information regarding the GPA interests under the contracts is registered with the SEC (See File No. XXX-XXXX).
Fee Table and Examples
Fee Table
a. COMMENT: In the Transaction Expenses – Surrender Charges section, make sure that the footnote (1) is in a smaller font size (usually 8pt) than the rest of the text.
RESPONSE: We confirm that the footnote (1) is the 8-pt. font size.
P a g e 5 | 19
b. COMMENT: In the “Annual Contract Expenses – Base Contract Expenses” section, remove the subheading “Annual Variable Account Expenses” and revise the statement in parenthesis “(as a percentage of average daily subaccount value)” to reflect that the percentage is the average daily variable account value.
c. RESPONSE: Revised as requested to read:
Base Contract Expenses
(as a percentage of average daily contract value in the variable account)
d. COMMENT: The Base Contract Expenses should include only the Standard Death benefit and the rest of the death benefits listed under the Base Contract Expenses – ROPP, MAV and 5-yearMAV, should be listed under the Optional Benefits.
RESPONSE: Revised as requested.
e. COMMENT: The values for the Mortality and Expense risk fees after the 10th contract year should be listed in the footnote and not a separate table.
RESPONSE: Revised as requested.
f. COMMENT: In the “Optional Benefit Expenses” section, the fee for the Benefit Protector Death Benefit rider should be listed as the current and maximum.
RESPONSE: Revised as requested.
g. COMMENT: Reverse the other of the SecureSource Legacy fees and list the most recent one first.
RESPONSE: Revised as requested.
h. COMMENT: In the Annual Funds Expenses, revise the statement in parenthesis and state that the expenses are deducted from the fund assets.
RESPONSE: Revised as requested.
Examples
a. COMMENT: Revise the language in the introductory paragraph, per Form N-4, Item 4.
b. RESPONSE: Revised to read:
These examples are intended to help you compare the cost of investing in the contract with the cost of investing in other variable annuity contracts. These costs include Transaction Expenses, Annual Contract Expenses, and Annual Fund expenses.
c. COMMENT: Change the investment amount assumption to “$100,000”.
RESPONSE: Revised as requested.
P a g e 6 | 19
Principal Risks of Investing in the Contract
a. COMMENT: Expand the Subaccount Risk to be broader and include the fixed account investment options.
RESPONSE: The Subaccount Risk is revised to read (change underlined):
Subaccount Risk. Amounts that you invest in the subaccounts are subject to the risk of poor investment performance. You assume the investment risk. Generally, if the subaccounts that you select make money, your contract value goes up, and if they lose money, your contract value goes down. Each subaccount’s performance depends on the performance of its underlying Fund. Each underlying Fund has its own investment risks, and you are exposed to the Fund’s investment risks when you invest in a subaccount. You are responsible for selecting subaccounts that are appropriate for you based on your own individual circumstances, investment goals, financial situation, and risk tolerance.
For risks associated with any Fixed Account options, see Financial Strength and Claims-Paying Ability Risk below.
b. COMMENT: Add the risk of the possibility of adverse tax consequences, per Form N-4, Item 5.
RESPONSE: The following risk is added:
Potential Adverse Tax Consequences. Tax considerations vary by individual facts and circumstances. Tax rules may change without notice. Earnings under your contract are generally taxed at ordinary income tax rates when withdrawn. You may have to pay a tax penalty if you take a withdrawal before age 59 1⁄2. If you purchase a qualified annuity to fund a retirement plan that is tax-deferred, your contract will not provide any necessary or additional tax deferral beyond what is provided in that retirement plan. Consult a tax professional.
The Variable Account and the Funds
a. COMMENT: Provide the name and address of the Depositor, per Form N-4, Item 6(a).
RESPONSE: The Company respectfully submits that the Depositor’s name and address are identified in the section “About the Service Providers – Issuer” and as such has made no further revision.
b. COMMENT: Revise the first sentence to indicate that the variable account consists of subaccounts.
RESPONSE: Revised to read (revision underlined):
P a g e 7 | 19
The variable account was established under Minnesota law on Aug. 23, 1995. The variable account, consisting of subaccounts, is registered as a single unit investment trust under the Investment Company Act of 1940 (the 1940 Act). This registration does not involve any supervision of our management or investment practices and policies by the SEC.
c. COMMENT: Revise the second paragraph to include a statement required by Form N-4, Item 6(b)(2) and (3).
RESPONSE: The second paragraph is revised to read:
The variable account meets the definition of a separate account under federal securities laws. Income, gains, and losses credited to or charged against the variable account reflect the variable account’s own investment experience and not the investment experience of RiverSource Life’s other assets. The variable account’s assets are held separately from RiverSource Life’s assets and are not chargeable with liabilities incurred in any other business of RiverSource Life. RiverSource Life is obligated to pay all amounts promised to contract owners under the contracts. The variable account includes other subaccounts that are available under contracts that are not described in this prospectus.
d. COMMENT: In the “Funds” subsection, add that the prospectus that contain more detailed information about the fund is available.
RESPONSE: Revised to read (change underlined):
These prospectuses containing more detailed information about the funds are available by contacting us at the 70100 Ameriprise Financial Center, Minneapolis, MN 55474, telephone: 1-800-862-799, Ameriprise.com/variable annuities.
e. COMMENT: Delete the statement in the Investment Objective subsection regarding the fund’s prospectuses as it is duplicative (already addressed in the previous paragraph).
RESPONSE: Revised as requested and deleted duplicative statement.
f. COMMENT: The use of the terms “funds”, “Investment options” is inconsistent – in this section, the new term “underlying investment” is introduced, and it can be confusing. Please revise and use consistent terminology.
RESPONSE: Revised to reflect consistent terminology.
The Guarantee Period Accounts (GPAs)/Market Value Adjustment (MVA)
COMMENT: Consider revising and abbreviation of the sections describing the GPAs and MVA since contract owners invested in the GPAs will get the stand-alone prospectus describing
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CORRESP
1
filename1.htm
CORRESP
November 18, 2021
Sonny Oh, Esq.
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
On behalf of RiverSource Variable Account 10
Post-Effective Amendment #7 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. Oh:
This letter, which we have filed as
Correspondence, responds to the comments we received on Oct. 18, 2021, with regard to the above-referenced Registration Statement which we filed on or about Sept. 3, 2021.
Comments and responses are outlined below.
Filing Cover
Page
COMMENT: Please provide the 33 Act Number to the cover page.
RESPONSE: The 33 Act number has been added to the filing cover page.
PROSPECTUS
General
COMMENT: Any comments made with respect to one specific part of the registration statement should result in disclosure changes to any other section of
the registration statement that addresses the same topic. Disclosure changes noted for the registration statement should be reflected in the related Initial Summary Prospectus and Updating Summary Prospectus, as appropriate.
RESPONSE: We will follow that approach.
Prospectus
Cover Page
a.
COMMENT: Fill out the date of the prospectus.
RESPONSE: The effective date of the prospectus will be added in the subsequent Post-Effective Amendments.
b.
COMMENT: Add the statement required by the Rule 481(b)(1) to the cover page.
P a g e 1 | 19
RESPONSE: The following statement is added to the cover page of the prospectus:
The Securities and Exchange Commission has not approved or disapproved these securities or determined if this prospectus is accurate
or complete. Any representation to the contrary is a criminal offense.
c.
COMMENT: If this is not a combination prospectus filed on the Form
S-3, delete the “RiverSource Account MGA” as part of the Registrant’s name.
RESPONSE: Revised as requested.
d.
COMMENT: In the first paragraph, use consistent name for the product as “Individual Flexible
Premium Deferred Combination fixed/variable annuity”.
e.
RESPONSE: Revised as requested.
f.
COMMENT: Please add a distribution channel variation to the last sentence in the first paragraph
RESPONSE: The first sentence in the first paragraph is revised to read (revision underlined):
All material terms and conditions of the contract, including material state variations and distribution
channels, are described in this prospectus.
Key Terms
a.
COMMENT: Revise key term describing the “Funds” to clearly define the funds relative to the
definition of subaccounts and variable account.
RESPONSE: The key term describing the Funds is revised and
an additional key term for the Subaccount is added:
Funds: Investment options under your contract, each with a different
investment objective. Each of the Subaccounts of the Variable Account invests in a specific one of these underlying funds.
Subaccount:
Each Subaccount is a separate investment division of the Variable Account and invests in a particular Fund.
b.
COMMENT: Revise the key term “Variable Account” and make sure that it is the same as the
RiverSource Variable Account 10.
RESPONSE: The key term is revised to read:
Variable Account: RiverSource Variable Account 10 consisting of Subaccounts, each of which invests in a particular Fund. The value of
your investment in each Subaccount changes with the performance of the particular Fund.
P a g e 2 | 19
Key Information Table
A. Fees and Expenses - Ongoing Fees and Expenses
a.
COMMENT: The table showing ongoing Fees and Expenses refers to the “Underlying Fund options”.
Please be consistent throughout the prospectus and use the consistent terminology when referring to the underlying funds.
RESPONSE: We have addressed this comment by revising the definition of Funds and Variable Account and adding a definition for
Subaccounts.
b.
COMMENT: Please confirm that Min/Max reflect contract administrative charge.
RESPONSE: Min/Max percentages in the table do not reflect the contract administrative charge fee. The footnote (1) has been revised
to read (changes underlined):
(1) As a percentage of average daily contract value in the variable account. The charge shown does
not include the contract administrative charge in the amount of $50 for contracts with contract value less than $50,000. This charge is waived for contracts with contract value of $50,000 or more.
c.
COMMENT: The footnote (1), refers to the “percentage of average daily subaccount value”. Since
the percentage reflects average daily value for all subaccounts that are part of the variable account, revise to reflect this. For example, change to “percentage of average daily variable account value”.
RESPONSE: The footnote is revised as shown under (b) above.
d.
COMMENT: Make sure that actual values in Min/Max depends on the rider selected and accurately describes
the values for the optional benefit selected.
RESPONSE: Confirmed.
e.
COMMENT: In the table showing the lowest and highest cost, revise the assumption terms to add a bullet
point with “No sales charge”, per Form N-4, Item 2 (ii)(B).
RESPONSE: The following bullet point is added:
•
No sales charge
P a g e 3 | 19
B. Risks
Risks Associated with Investment Options
COMMENT: Revise the second bullet point to reflect that each investment option (including any fixed account investment option) will have
its own unique risks, per Form N-4, Item 2. Instructions (3)(C).
RESPONSE: The second
bullet point is revised to read:
•
Each investment option (including under any fixed account investment options) has its own unique risks.
Investments
a.
COMMENT: Change the title of the section to “Investments”, per Form N-4, Item 2.
RESPONSE: Revised as requested.
b.
COMMENT: Revise the statement in the last bullet point to reflect consistent naming for the funds.
RESPONSE: Revised to read:
We reserve the right to add, remove or substitute funds as investment options. We also reserve the right, upon
notification to you, to close or restrict any funds.
Optional Benefits
COMMENT: Please break the first bullet into more bullet points to easier follow the restrictions.
RESPONSE: The optional benefits restrictions are revised as follows:
•
Certain optional benefits limit or restrict the investment options you may select under the Contract. If you
later decide you do not want to invest in those approved investment options, you must request a full surrender.
•
Certain optional benefits may limit subsequent purchase payments.
•
Withdrawals in excess of the amount allowed under certain optional benefits may substantially reduce the benefit
or even terminate the benefit.
•
We may stop offering an optional benefit at any time for new sales.
C. Taxes
a.
COMMENT: Revise first bullet point to specify that the tax implications are for the investment in and
purchase payments received under the contract, per Form N-4 Item 2 Instructions (5).
RESPONSE: Revised to read:
•
Consult with a tax advisor to determine the tax implications of an investment in and purchase payments
received under this Contract.
b.
COMMENT: In the second bullet point, please clarify that there is no additional tax benefits for the
investor if the contract is purchased through the tax-qualified plan or IRA, per Form N-4, Item 2 Instructions (5).
P a g e 4 | 19
RESPONSE: Revised to read:
•
If you purchase the Contract through a tax-qualified plan or
individual retirement account, you do not get any additional tax benefit.
D. Conflicts of Interest
COMMENT: Under “Investment Professional Compensation”, replace the term “additional compensation” with the
term “financial incentive”.
RESPONSE: Revised as requested.
Overview of the Contract
a.
COMMENT: In the Accumulation Phase paragraph, specify that the DCA Account is the Special DCA Fixed
Account.
RESPONSE: Revised as requested.
b.
COMMENT: Prominently disclose that additional information about each fund is provided in an appendix to
the prospectus, per Form N-4 Item 3 (b), Instructions (1).
RESPONSE: The
disclosure is bolded and revised to read:
A list of funds and additional information regarding each fund in
which you can invest is provided in Appendix A — Funds Available Under the Contract.
c.
COMMENT: Provide brief description of the GPA s and MVA with a cross-reference to the GPA prospectus
filed on Form S-3.
d.
RESPONSE: The following disclosure is added:
The GPAs have guaranteed interest rates for guarantee periods we declare when you allocate purchase payments or transfer contract value to
them. A positive or negative MVA is assessed if any portion of a Guarantee Period Account is surrendered or transferred more than thirty days before the end of its guarantee period. A prospectus containing more information regarding the GPA
interests under the contracts is registered with the SEC (See File No. XXX-XXXX).
Fee Table and Examples
Fee Table
a.
COMMENT: In the Transaction Expenses – Surrender Charges section, make sure that the footnote
(1) is in a smaller font size (usually 8pt) than the rest of the text.
RESPONSE: We confirm that the
footnote (1) is the 8-pt. font size.
P a g e 5 | 19
b.
COMMENT: In the “Annual Contract Expenses – Base Contract Expenses” section, remove the
subheading “Annual Variable Account Expenses” and revise the statement in parenthesis “(as a percentage of average daily subaccount value)” to reflect that the percentage is the average daily variable account value.
c.
RESPONSE: Revised as requested to read:
Base Contract Expenses
(as a percentage of average daily contract value in the variable account)
d.
COMMENT: The Base Contract Expenses should include only the Standard Death benefit and the rest
of the death benefits listed under the Base Contract Expenses – ROPP, MAV and 5-yearMAV, should be listed under the Optional Benefits.
RESPONSE: Revised as requested.
e.
COMMENT: The values for the Mortality and Expense risk fees after the 10th contract year should be listed in the footnote and not a separate table.
RESPONSE: Revised as requested.
f.
COMMENT: In the “Optional Benefit Expenses” section, the fee for the Benefit Protector Death
Benefit rider should be listed as the current and maximum.
RESPONSE: Revised as requested.
g.
COMMENT: Reverse the other of the SecureSource Legacy fees and list the most recent one first.
RESPONSE: Revised as requested.
h.
COMMENT: In the Annual Funds Expenses, revise the statement in parenthesis and state that the expenses
are deducted from the fund assets.
RESPONSE: Revised as requested.
Examples
a.
COMMENT: Revise the language in the introductory paragraph, per Form
N-4, Item 4.
b.
RESPONSE: Revised to read:
These examples are intended to help you compare the cost of investing in the contract with the cost of investing in other variable
annuity contracts. These costs include Transaction Expenses, Annual Contract Expenses, and Annual Fund expenses.
c.
COMMENT: Change the investment amount assumption to “$100,000”.
RESPONSE: Revised as requested.
P a g e 6 | 19
Principal Risks of Investing in the Contract
a.
COMMENT: Expand the Subaccount Risk to be broader and include the fixed account investment options.
RESPONSE: The Subaccount Risk is revised to read (change underlined):
Subaccount Risk. Amounts that you invest in the subaccounts are subject to the risk of poor investment performance. You
assume the investment risk. Generally, if the subaccounts that you select make money, your contract value goes up, and if they lose money, your contract value goes down. Each subaccount’s performance
depends on the performance of its underlying Fund. Each underlying Fund has its own investment risks, and you are exposed to the Fund’s investment risks when you invest in a subaccount. You are responsible for
selecting subaccounts that are appropriate for you based on your own individual circumstances, investment goals, financial situation, and risk tolerance.
For risks associated with any Fixed Account options, see Financial Strength and Claims-Paying Ability Risk below.
b.
COMMENT: Add the risk of the possibility of adverse tax consequences, per Form N-4, Item 5.
RESPONSE: The following risk is added:
Potential Adverse Tax Consequences. Tax considerations vary by individual facts and circumstances. Tax rules may change without notice.
Earnings under your contract are generally taxed at ordinary income tax rates when withdrawn. You may have to pay a tax penalty if you take a withdrawal before age 59
1⁄2. If you purchase a qualified annuity to fund a retirement plan that is tax-deferred, your contract will not provide any
necessary or additional tax deferral beyond what is provided in that retirement plan. Consult a tax professional.
The Variable Account and
the Funds
a.
COMMENT: Provide the name and address of the Depositor, per Form
N-4, Item 6(a).
RESPONSE: The Company respectfully submits
that the Depositor’s name and address are identified in the section “About the Service Providers – Issuer” and as such has made no further revision.
b.
COMMENT: Revise the first sentence to indicate that the variable account consists of subaccounts.
RESPONSE: Revised to read (revision underlined):
P a g e 7 | 19
The variable account was established under Minnesota law on Aug. 23, 1995. The variable account, consisting of subaccounts, is registered as
a single unit investment trust under the Investment Company Act of 1940 (the 1940 Act). This registration does not involve any supervision of our management or investment practices and policies by the SEC.
c.
COMMENT: Revise the second paragraph to include a statement required by Form N-4, Item 6(b)(2) and (3).
RESPONSE: The second paragraph is revised to read:
The variable account meets the definition of a separate account under federal securities laws. Income, gains, and losses credited to
or charged against the variable account reflect the variable account’s own investment experience and not the investment experience of RiverSource Life’s other assets. The variable account’s assets
are held separately from RiverSource Life’s assets and are not chargeable with liabilities incurred in any other business of RiverSource Life. RiverSource Life is obligated to pay all amounts promised
to contract owners under the contracts. The variable account includes other subaccounts that are available under contracts that are not described in this prospectus.
d.
COMMENT: In the “Funds” subsection, add that the prospectus that contain more detailed
information about the fund is available.
RESPONSE: Revised to read (change underlined):
These prospectuses containing more detailed information about the funds are available by contacting us at the 70100
Ameriprise Financial Center, Minneapolis, MN 55474, telephone: 1-800-862-799, Ameriprise.com/variable annuities.
e.
COMMENT: Delete the statement in the Investment Objective subsection regarding the fund’s
prospectuses as it is duplicative (already addressed in the previous paragraph).
RESPONSE: Revised as requested
and deleted duplicative statement.
f.
COMMENT: The use of the terms “funds”, “Investment options” is inconsistent –
in this section, the new term “underlying investment” is introduced, and it can be confusing. Please revise and use consistent terminology.
RESPONSE: Revised to reflect consistent terminology.
The Guarantee Period Accounts (GPAs)/Market Value Adjustment (MVA)
COMMENT: Consider revising and abbreviation of the sections describing the GPAs and MVA since contract owners invested in the
GPAs will get the stand-alone prospectus describing