Fixed No standard fixed accounts

3,5, 7, 10 yr MVA accts

6 & 12 month DCA accts in all states

Variable 45

• Morgan Stanley Investment Management,
• Morgan Stanley Investment Advisors ,
• Morgan Stanley Investments ,
• Van Kampen,
• AIM,
• Alliance ,
• Franklin Templeton ,
• Putnum

$10,000 NQ and $2,000 Qualified

$1,000 ($50 if auto add)

12 transfers per contract year without charge; 1.0% of the amount transferred thereafter.

DCA & Auto Rebalance not included in 12 transfers. Minimum transfer of $500 to any fixed account and $100 to any variable sub-acct.

Transfer or withdrawal from fixed acct is limited to 30% of starting value in bucket. No transfers to DCA accts.

15% of purchase payments

Greater of

1) sum of all purchase payments, adjusted for withdrawals

2) Contract Value or

3) Settlement Value

[All riders may not be available in all states]

Enhanced Beneficiary Protection Rider A: (5% Annual Increase) Max issue age = 79. Benefit lock-in to age 80.

Enhanced Beneficiary Protection Rider B: Maximum Anniversary Value (MAV) Max issue age = 79. Benefit lock-in to age 80.

EEDB - Max issue age = 79;

Earnings enhanced 40% of gains up to 100% of premium, for issue ages 0-70;

Earnings enhanced 25% of gains up to 50% of prem, for issue ages 71-79.

Spousal Protection Benefit Rider - Bumps Contract Value up to death benefit value on death of co-annuitant (spouse of owner/annuitant). Only available for custodial, Roth, SEP & Traditional IRAs. Max issue age = 79 for co-annuitant. Restrictions on add-arider.

[All riders may not be available in all states]

TrueReturn Accumulation Benefit Rider - Guarantees a minimum account value, on a specified date (rider matruity date), which is payable as long as the contract is still in the accumulation phase. On the rider maturity date, if the accumulation benefit is greater than the account value, the account value will be increased to equal the accumulation benefit.

Choice of two different guarantee options;

Option 1 = More conservative model with rider periods from eight to twenty years;

Option 2 = More moderate model with rider periods ten to twenty years. Specific fund allocations needed for obtaining the guarantee option factor chosen. Rider maturity date must occur before the latest payout start date. May be cancelled at any time on or after the 5th rider anniversary.

[All riders may not be available in all states] Contract available only with Withdrawal Charge Option Rider 1, which amends policy to have a 3 yr surrender charge schedule.

Income Protection Benefit Rider - floor on var income payments of 85% of initial income payments. Available only on the payout start date. Max issue age = 75. Charitable Remainer Trust & Grantor Trust endorsements apply.

[All riders may not be available in all states]

SureIncome Withdrawal Benefit Option - Guarantees the ability to withdraw total guaranteed amount over time as long as withdrawals stay within prescribed limits.

Withdrawals in excess of limits may reset guarantees under the rider. Total guaranteed amount is equal to the contract value at rider issue plus all subsequent purchase payments. The prescribed withdrawal limit is 8% of contract value at rider issue plus 8% of all subsequent purchase payments.

Certain variable funds and standard/ Maximum Anniversary Value fixed accounts not allowed with rider. Max issue age = 80 CW, 75 NY.

No 403(b) business (frozen or otherwise allowed). May be cancelled or traded-in at any time on or after the 5th rider anniversary.

Asset Allocation? Yes

Auto Additions? Yes

Dollar Cost Averaging? Yes

Nursing Home Waiver? Yes

Widow Waiver? Yes

Terminal illness Waiver? Yes

Required Min Distribution (RMD) Waiver? Yes

Systematic Withdrawals? Yes

Spousal Continuation? Yes

IRA 2000 Availability? Yes