Variable Annuity Contract Comparison Report

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March 4, 2008

2 General Contract Information

5 Optional Benefit Descriptions

6 Special Features & Annuitization

7 Withdrawal & Transfer

8 Investment Options

11 Historical Benefit Summary

12 Disclosure

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General Contract Information

Independence

Principal Variable Annuity

as of prospectus dated 05-01-2007 as of prospectus dated 05-01-2007

... ... Policy Inception 07-27-1990 Type VA Subaccounts 12 Share Class B Policy Inception 06-01-1994 Type VA Subaccounts 47 Share Class B

Insurance Company Information

Contact Information Contact Information

John Hancock Life Insurance Co (USA) 500 N. Woodward Avenue

Bloomfield Hills, MI 48304 617-572-9950

Principal Life Insurance CO Principal Financial Group Des Moines, IA 50392 800-852-4450

Rating Information

A.M. Best A++

Prospectus Date 05-01-2007 Supplement Date NA Rating Information A.M. Best A+ Prospectus Date 05-01-2007 Supplement Date NA Purchase Information

Open for New Investment No

Premium type Flexible

Product Availability

Simple IRA, 401a, IRA Rollover, 408k (SARSEP), SEP/IRA, Roth IRA, IRA, 457 Deferred Compensation, 403b, Non-Qualified.

Unavailable in all states

Open for New Investment No

Premium type Flexible

Product Availability

Simple IRA, IRA Rollover, SEP/IRA, IRA, Non-Qualified. Available in all states

Qualified Limitations

Max. Owner Issue Age 84

Max. Annuitant Issue Age 84

Min. Initial Purchase Payment $— Min. Additional Purchase Payment $50

...

Non-Qualified Limitations

Additional Purchase Information

THIS PRODUCT IS NO LONGER AVAILABLE FOR NEW SALES.

Qualified Limitations

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Non-Qualified Limitations

Additional Purchase Information

Pension Trust arrangements also available. For contracts issued in New Jersey after first contract year, purchase payments cannot exceed $100,000 per contract year. Fixed Account is not available if purchase payment credit rider is selected in Oregon. Initial and Subsequent payments must average at least $100 and can not be less than $50 for members of a retirement plan covering 3 or more persons.

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General Contract Information

Independence

Principal Variable Annuity

Base Contract Charges

M&E Note M&E Note

variable investment options only. variable investment options only.

Administrative Charge Note Administrative Charge Note

Admin Fee Note: variable investment options only. Admin Fee Note: N/A

Distribution Charge Note Distribution Charge Note

Dist. Fee Note: N/A Dist. Fee Note: N/A

Contingent Deferred Surrender Charges (CDSC)

Class Name Schedule % Max. Charge % Max. Years B-share-Share* 8, 8, 8, 7, 7, 6, 6 8.00 7 *Used to calculate standardized returns.

CDSC Note

As a percentage of purchase payments liquidated:

Class Name Schedule % Max. Charge % Max. Years B-Share-Share 6, 6, 6, 5, 4, 3, 2 6.00 7 R-Share-Share* 8, 8, 8, 8, 7, 6, 5, 4, 3 8.00 9 *Used to calculate standardized returns.

CDSC Note

If owner elects Premium Payment Credit Rider, nine-year surrender charge schedule will apply. The seven-year surrender charge is standard and is deducted as a percentage of purchase payments liquidated:

Initial Sales Charges

None None

Benefit Summary

Death Benefits

Standard Death Benefit Age 74 /Undr Valuation Basis*

PP, AV

Max Issue Age Rider Charges % Charge Basis Benefit Type

74 0.00 Basic Basic

Standard Death Benefit Age 75 + Valuation Basis*

AV

NA 0.00 Basic Basic

Enhanced Death Benefit Valuation Basis* PP, AV, 5.00% RF, MAV

Max Issue Age Rider Charges % Charge Basis Benefit Type NA 0.05 Combination Combination

Standard Death Benefit Valuation Basis* PP, AV, 7.00-yr MAV

NA 0.00 MAV MAV

*PP=Purchase Payments, AV=Account Value, MAV=Maximum Anniversary Value, RF=Rising Floor, BV=Benefit Value, NAR=Net Amount at Risk

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General Contract Information

Independence

Principal Variable Annuity

... ... Policy Inception 07-27-1990 Type VA Subaccounts 12 Share Class B Policy Inception 06-01-1994 Type VA Subaccounts 47 Share Class B Benefit Summary

Living Benefits / Special Features

Purchase Payment Credit Valuation Basis* NA

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Optional Benefit Descriptions

Independence

Principal Variable Annuity

... ... Policy Inception 07-27-1990 Type VA Subaccounts 12 Share Class B Policy Inception 06-01-1994 Type VA Subaccounts 47 Share Class B Death Benefits

Benefit Name Additional Charge%

Standard Death Benefit 0.00

...

Prior to annuitization, upon death of annuitant before contract anniversary nearest annuitant's 75th birthday - greater of 1) contract value or 2) purchase payments less withdrawals and applicable charges; upon death of annuitant on or after contract anniversary nearest annuitant's 75th birthday - contract value. If spouse is beneficiary, he/she may elect to continue contract as contract owner instead of receiving death benefit.

Enhanced Death Benefit 0.05

...

Available at contract issue (except in New Jersey and Washington) for an additional charge of 0.05% of average quarterly contract value; once terminated cannot be reinstated; rider provides the greater of enhanced death benefit or standard death benefit; prior to the annuitization date and prior to the lock-in date (the later of the contract anniversary following the oldest owner's 75th birthday or five years after the rider effective date), upon death of owner, joint owner, or annuitant (if owner is entity) - enhanced death benefit is greater of a) purchase payments less withdrawals and applicable charges, accumulated at 5% annually; or b) highest contract value on any contract anniversary; plus premium payments received since that contract anniversary; minus partial surrender. After lock-in date - a) and b) are only increased by premium payment and decreased by adjustment for partial surrender since the lock-in date. For contracts issued in New York - of 1) contract value, 2) purchase payments less withdrawals and applicable charges, 3) highest contract value on any contract anniversary until annuitant's 75th birthday or five years from rider issue, adjusted for purchase payments, withdrawals, and applicable charges since that contract anniversary. For further details, please consult prospectus or with Issuer.

Standard Death Benefit 0.00

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Prior to annuitization, upon death of owner, joint owner, or annuitant (if owner is entity) -greatest of 1) contract value, 2) purchase payments less withdrawals and applicable charges, 3) highest seven-year step-up value, adjusted for purchase payments and withdrawals since that anniversary. If spouse is beneficiary, he/she may elect to continue contract as owner instead of receiving death benefit.

Living Benefits

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Special Features & Annuitization

Independence

Principal Variable Annuity

... ... Policy Inception 07-27-1990 Type VA Subaccounts 12 Share Class B Policy Inception 06-01-1994 Type VA Subaccounts 47 Share Class B Bonus Features

N/A Available at contract issue for an additional annual charge of 0.60% of average daily net assets of separate accounts for first eight contract years; once elected, rider cannot be terminated; may not be available in all states; may not participate in DCA Plus Program; rider provides a 5% credit on all purchase payments made during first contract year; upon election of rider nine-year surrender charge, based on the percentage of purchase payments liquidated, applies. For further details, please consult prospectus or with Issuer.

Other Features Available

N/A N/A

Surrender Charge Waivers

Death Disability Death Terminal Illness Hospital Nursing Home Annuitization Options Summary

Max Annuitant Start Age 85

Fixed Yes

Variable Yes

Variable AIR% 3.50

Payout Options

Life Annuity with Payments for a Guaranteed Period - 20 Years Life Annuity with Payments for a Guaranteed Period - 10 Years Life Annuity with Payments for a Guaranteed Period - 5 Years Life Annuity without Further Payment on Death of Payee

Summary

Max Annuitant Start Age

-Fixed No

Variable Yes

Variable AIR%

-Payout Options

Fixed Period Income Joint and Survivor - Other

Joint and Survivor with Period Certain - Other Joint and Two-Thirds Survivor Life Income - 66 2/3 Life Income

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Withdrawal & Transfer

Independence

Principal Variable Annuity

... ... Policy Inception 07-27-1990 Type VA Subaccounts 12 Share Class B Policy Inception 06-01-1994 Type VA Subaccounts 47 Share Class B Withdrawal Details Free Withdrawal

10% of contract value as of beginning of contract year; noncumulative; minimum - $250 or remaining option value, if less; minimum remaining contract value - $1,000.

Free Withdrawal

Greater of 1) earnings or 2) 10% of purchase payments, decreased by partial surrender; noncumulative; minimum - $100; minimum remaining contract value - $5,000.

Systematic Withdrawal

Available on a monthly, quarterly, semiannual, or annual basis; minimum - $250; minimum remaining contract value - $5,000; free withdrawal amount applies; not available in conjunction with dollar cost averaging.

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Note: Taxes may be payable upon withdrawal. A 10% IRS penalty may apply to withdrawals prior to age 59 1/2.

Systematic Withdrawal

Available on a monthly, quarterly, semiannual, or annual basis; minimum qualifying contract value - $5,000.

...

Note: Taxes may be payable upon withdrawal. A 10% IRS penalty may apply to withdrawals prior to age 59 1/2.

Transfer Details

General Transfer Information

Prior to annuitization, unlimited among variable investment options, and at no charge; to Fixed Account - may not exceed $100,000 per contract year; from Fixed Account - once per contract year, within 30 days after a contract anniversary, and limited to greater of 1) $500 or 2) 20% of Fixed Account value; maximum - $500,000 to any one variable investment option per contract year; not available within 30 days prior to annuitization; available by telephone, fax, or written request. After annuitization, limited to use of four variable investment options at any one time; to or from Fixed Account - not permitted.

General Transfer Information

Prior to annuitization, unlimited among variable investment options and Fixed Account, and at no charge; minimum amount transferable - $100 or option value, if less; to Fixed Account - not permitted if a transfer has been made from Fixed Account within six months or if Fixed Account value would be greater than $1,000,000; from Fixed Account - once per contract year, 1) cannot excceed 25% of Fixed Account accumulated value, or 2) 100% of Fixed Account accumulated value if Fixed Account accumulated value is less than $1,000 or renewal interest rate for current contract year is more than one percentage point lower than weighted average of Fixed Account interest rates for the preceding contract year; to DCA Plus Accounts - not permitted; available by telephone, fax, written request or electronically. After annuitization - not permitted.

Systematic Transfer

Dollar Cost Averaging: Available on a monthly, quarterly, semiannual, or annual basis from any variable investment option to any other variable investment option(s); to or from Fixed Account - not permitted; duration available - 12, 24, or 36 months; minimum qualifying contract value - $15,000; minimum - $100; not available in conjunction with systematic withdraeal; program continues until cancellation occurs, duration expires, or source account is depleted.

Enhanced Dollar Cost Avg: N/A

Asset Rebalancing Frequency: Quarterly, Semi-Annually, Annually.

Systematic Transfer

Dollar Cost Averaging: Available on a monthly, quarterly, semiannual, or annual basis; from Fixed Account - available on a monthly basis to variable investment option(s); to DCA Plus Amounts - not permitted; minimum qualifying Fixed Account value - $5,000; transfers of amount not to exceed 2% of Fixed Account value; minimum transfer amount with Fixed Accounts - $100 or option value, if less; programs continue until source account is depleted or cancellation occurs.

Enhanced Dollar Cost Avg: DCA Plus Program - available on a monthly basis from DCA Plus Account to any other investment option; minimum purchase payment - $1,000; program duration - 6 month and 12 month; only one 6-month and one 12-month DCA Plus program are available at one time. May not be available in conjunction with purchase payment bonus and asset rebalancing. Please refer to prospectus for details or consult with Issuer.

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Investment Options

Independence

Principal Variable Annuity

as of 02-29-2008 as of 02-29-2008 ... ... Policy Inception 07-27-1990 Type VA Subaccounts 12 Share Class B Policy Inception 06-01-1994 Type VA Subaccounts 47 Share Class B Summary as of 02-29-2008 Features

Fixed Account Not Available

DCA Fixed Account Yes

Asset Allocation No Rebalancing Yes DCA Yes Enhanced DCA No Earnings Sweep No Features

Fixed Account Not Available

DCA Fixed Account Yes

Asset Allocation No

Rebalancing Yes

DCA Yes

Enhanced DCA Yes

Earnings Sweep No

Subaccount Total Expense

Highest 2.55

Median 2.08

Lowest 1.65

Average 2.17

Subaccount Total Expense

Highest 2.69

Median 2.01

Lowest 1.37

Average 1.94

Advisor/Subadvisor Summary as of 02-29-2008

John Hancock Investment Mgmt S/Declaration Management & Resea John Hancock Investment Mgmt S/Independence Investments LLC John Hancock Investment Mgmt S/SSgA Funds Management Inc John Hancock Investment Mgmt S/Price Rowe T Services Inc /ta John Hancock Investment Mgmt S/MFC Global (U.S.A.)

John Hancock Investment Mgmt S/Capital Guardian Trust Company John Hancock Investment Mgmt S/Wellington Management Company,

A I M Advisors, Inc. American Century Inv. Mgmt.

Fidelity Mgmt & Research (FMR)/Fidelity Intl Investment Adv, Janus Capital Management LLC

Principal Management Corporati/Morgan Stanley Investment Mgt Principal Management Corporati/Principal Global Investors Principal Management Corporati/Principal Global Investors, LL Principal Management Corporati/Price Rowe T Services Inc /ta Principal Management Corporati/Edge Asset Management Principal Management Corporati/Columbus Circle Investors Principal Management Corporati/AllianceBernstein L.P. Principal Management Corporati/Mellon Equity Associates LLP Principal Management Corporati/Neuberger Berman Management In Principal Management Corporati/Principal Real Estate Investor Principal Management Corporati/UBS Global Asset Mgmt (new Yor Principal Management Corporati/JPMorgan Investment Management

Subaccounts Available as of 02-29-2008

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Investment Options

Independence

Principal Variable Annuity

as of 02-29-2008 as of 02-29-2008 ... ... Policy Inception 07-27-1990 Type VA Subaccounts 12 Share Class B Policy Inception 06-01-1994 Type VA Subaccounts 47 Share Class B

Style Box Distribution as of 02-29-2008

Equity Style Distribution

Value Blend Growth

Small

Mid

Large 0 5 0

1 0 1 1 0 0

Total Equity Subaccounts: 8

Equity Style Distribution

Value Blend Growth

Small

Mid

Large 7 7 17

1 1 5 1 1 2

Total Equity Subaccounts: 42

Fixed Income Style Distribution

Sht Int Lng Low Med Hi 1 3 0 0 0 0 0 0 0

Total Fixed-Income Subaccounts: 4

Fixed Income Style Distribution

Sht Int Lng Low Med Hi 1 9 0 0 3 0 0 0 0

Total Fixed-Income Subaccounts: 13

Star Ratings as of 02-29-2008

Five Stars QQQQQ

JH Ind-JHT Intl Eqty Idx B NAV JH Ind-JHT Small Cap Value NAV

Five Stars QQQQQ

Principal-Fidelity VIP Contrafd Svc Principal-Principal Divrsfd Intl Principal-Principal Equity Income 1 Principal-Principal SAM Cons Gr 1

Four Stars QQQQ

JH Ind-JHT Mid Value Trust NAV JH Ind-JHT Small Cap Growth NAV

Four Stars QQQQ

Principal-AIM VI Core Equity 1 Principal-AIM VI Small Cap Equity 1 Principal-Fidelity VIP Growth Svc Principal-Janus Asp Md Cp Gr Svc Principal-Principal Asset Allocatio

...

Principal-Principal Intl Emerging M Principal-Principal MidCap Principal-Principal SAM Balanced 1 Principal-Principal SAM Strat Gr 1

Three Stars QQQ

JH Ind-JHT 500 Index Trust B NAV JH Ind-JHT Active Bond NAV JH Ind-JHT Bond Index Trust B Se JH Ind-JHT Short-Term Bond Tr NAV

Three Stars QQQ

Principal-AIM VI Dynamics 1 Principal-AIM VI Global Health 1 Principal-AmCent VP Value II Principal-Fidelity VIP Eq Inc Svc2 Principal-Principal Balanced

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...

Investment Options

Independence

Principal Variable Annuity

as of 02-29-2008 as of 02-29-2008 ... ... Policy Inception 07-27-1990 Type VA Subaccounts 12 Share Class B Policy Inception 06-01-1994 Type VA Subaccounts 47 Share Class B Star Ratings as of 02-29-2008 Three Stars QQQ

Principal-Principal Govt & Hi QlyBd Principal-Principal Growth Principal-Principal Intl SmallCap Principal-Principal LargeCap Stk In Principal-Principal MidCap Growth

...

Principal-Principal MidCap Value Principal-Principal Real Estate Sec Principal-Principal SAM Cons Bal 1 Principal-Principal SAM Flex Inc 1 Principal-Principal SmallCap

...

Principal-Principal SmallCap Growth Principal-Principal SmallCap Value

Two Stars QQ

JH Ind-JHT Growth & Income 2 NAV JH Ind-JHT Managed Trust Ser NAV JH Ind-JHT Overseas Equity NAV

Two Stars QQ

Principal-AIM VI Capital Apprec 1 Principal-AIM VI Technology 1 Principal-AmCent VP In&Gr I Principal-Principal Bond Principal-Principal Capital Value

...

Principal-Principal Equity Growth Principal-Principal LargeCap Blend Principal-Principal LargeCap Value Principal-Principal Short-Term Bond

One Star Q

None

One Star Q

Principal-AmCent VP Ultra I

Not Rated

JH Ind-JHT Money Market Trust B NAV

Not Rated Principal-Principal LifeTime 2010 Principal-Principal LifeTime 2020 Principal-Principal LifeTime 2030 Principal-Principal LifeTime 2040 Principal-Principal LifeTime 2050 ...

Principal-Principal LifeTime StrInc Principal-Principal Money Market

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Historical Benefit Summary

Independence

Principal Variable Annuity

Historical Benefit Summary

Death Benefits

Enhanced Death Benefit

Valuation Basis* Start Date End Date 0.05% RF, MAV 06-01-1994 present Max Issue Age Rider Charges % Charge Basis Benefit Type

85 0.05 AV Combination

STD DB

Valuation Basis* Start Date End Date 7.00-yr MAV 06-01-1994 present Max Issue Age Rider Charges % Charge Basis Benefit Type

85 0.00 N/A MAV

*PP=Purchase Payments, AV=Account Value, MAV=Maximum Anniversary Value, RF=Rising Floor, BV=Benefit Value, NAR=Net Amount at Risk

Historical Benefit Summary

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The VA Contract Comparison Report is supplemental sales material and therefore must be preceded or accompanied by the current prospectus, or equivalent, of the subaccounts, a variable annuity contract and this disclosure statement.

The VA Contract Comparison Report provides an in-depth overview of the features of a particular variable annuity (VA) contract. An annuity is a tax-deferred investment structured to convert a sum of money into a series of payments over time. Variable annuity policies have limitations and are not viewed as short-term liquid investments. An insurance company's fulfillment of a commitment to pay a minimum death benefit, a schedule of payments, a fixed investment account guaranteed by the insurance company, or another form of guarantee depends on the claims-paying ability of the issuing insurance company. Any such guarantee does not affect or apply to the investment return or principal value of the separate account and its subaccount.

The financial ratings quoted for an insurance company do not apply to the separate account and its subaccount. Variable annuity contracts are not FDIC-insured, may lose money, and are not guaranteed by a bank or other financial institution. If the variable annuity subaccount is invested in a money-market fund, that investment in the fund is not insured or guaranteed by the FDIC or any other government agency. Although the money market seeks to preserve a stable per share value (i.e. $1.00 per share), it is possible to lose money by investment in the fund.

The performance data given represents past performance and should not be considered indicative of future results. Principal value and investment return will fluctuate, so that an investor's units when redeemed may be worth more or less than the original investment.

All data presented is based on the most current information available to Morningstar, Inc. The information contained in this report is from the most recent information available to Morningstar as of the release date, and may or may not be an accurate reflection of the current composition of the securities included in the portfolio. There is no assurance that the data will remain the same.

Morningstar Associates, LLC, a registered investment advisor and wholly owned subsidiary of Morningstar, Inc., provides various institutional investment consulting services, including asset allocation advice to financial institutions who have or will be creating a fund-of-fund/ asset allocation product. However, despite the fact that such a relationship may exist, the information displayed for those products will not be influenced as they are derived from the annuity's prospectus and are objective measures and/or are derived by quantitative driven formulas (i.e. Morningstar Rating).

Investment Risks

High-Yield Bond Subaccounts: The investor should note that subaccounts that invest in lower-rated debt securities (commonly referred to as junk bonds) involve additional risks because of the lower credit quality of the securities in the portfolio. The investor should be aware of the possible higher level of volatility and increased risk of default.

International /Emerging Market Subaccounts: The investor should note that subaccounts that invest in international securities involve special additional risks. These risks include, but are not limited to, currency risk, political risk, and risk associated with varying accounting

companies with smaller market capitalizations involve additional risks. The securities of these companies may be more volatile and less liquid than the securities of larger companies.

Non-Diversified Subaccounts: The investor should note that subaccounts that invest more of their assets in a single issuer involve additional risks, including share price fluctuations, because of the increased concentration of investments.

Sector Subaccounts: The investor should note that subaccounts that invest exclusively in one sector or industry involve additional risks. The lack of industry diversification subjects the investor to increased industry-specific risks.

Small Cap Subaccounts: The investor should note that subaccounts that invest in stocks of small companies involve additional risks. Smaller companies typically have a higher risk of failure and are not as well established as larger blue-chip companies. Historically, smaller-company stocks have experienced a greater degree of market volatility than the overall market average.

Basics

Annuity Options:

Maximum Annuitant Start Age is the highest age at which an annuitant can begin to receive annuity paymemts.

Fixed: Annuity payments are made based on a fixed return (fixed rate of interest) and mortality factors.

Variable: Annuity payments are made based on a variable return and age and mortality factors.

Variable AIR% is the assumed interest rate available at the point of annuitizing a contract using a variable annuitization option. The assumed interest rate and mortality factors are used calculate the amount of the initial payout. Subsequent payments will be lower or higher based on the actual returns of the investment options selected.

Bonus is a provision in a VA contract whereby the insurer credits the contract with a percentage of the investment made into the contract by the investor, or based on contract value achieved. This provision is typically accompanied by a higher level of contract/rider expense.

Contract Type includes closed [c], open [O], non-group open [NGO], immediate variable annuity [IMVA], limited availability [LA], and non-group open/limited availability [NGO/LA].

Contract Charges

Contract Charge is the yearly fee charged to compensate the insurance company for the cost of maintaining and administering the variable annuity policy.

Surrender Charges are deducted from a policy if an investor makes a withdrawal prior to a specified time.

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Death benefits are typically calculated as the greater of several values, including contract value, premiums applied, maximum anniversary value, rising floors, an enhanced earnings benefits. Death benefit guarantees are subject to the claims-paying ability of the insurance company.

Contract value: The market value of all subaccounts and fixed options held in the contract.

Premiums: Investments made into the VA contract.

MAV: Maximum anniversary value is a death benefit that provides a floor of protection equal to the highest contract value of all contract anniversary dates.

Rising Floor: A death benefit that provides a floor of death benefit protection equal to the policy premiums accumulated at a stated guaranteed annual rate.

EEB: Earnings enhancement bonus. This feature enables beneficiaries to receive an additional percentage of policy earnings when death benefits are paid out.

Dollar Cost Averaging is a contract transfer strategy whereby dollars are transferred on a regular schedule from a fixed account to selected subaccounts. Interest rates are applied to a declining balance in the fixed account. Dollar cost averaging does not assure a profit and does not protect against loss in declining markets.

Earnings Sweep is a contract transfer strategy whereby earnings from a fixed account are diverted into selected subaccounts.

Insurance Expenses

Administration Fees are the percentage of the subaccount's assets that the insurance company deducts to cover the costs involved in offering and administering the subaccount, such as the cost of distribution and printing of correspondence.

Distribution charges are intended to compensate the insurance company for a portion of its acquisition expenses under the annuity, including promotion and distribution of the annuity and costs associated with its offering. The distribution charge is typically deducted against the policy holders' annuity account value.

M&E Risk Charge--the mortality and expense risk charge--is the percentage of the subaccount's assets that the insurance company deducts to cover costs associated with mortality and expense risk. The typical M&E risk charge for variable annuity subaccounts is about 1.2%, as calculated by Morningstar as of 12-31-05.

Total Insurance Expense is the percentage of subaccount assets deducted each year to cover M&E risk charges, and other miscellaneous administration fees. This information is taken directly from the insurance policy's prospectus.

Living Benefits are subject to the claims-paying ability of the insurance company and include the following:

Guaranteed Minimum Income Benefit (GMIB): A living benefit that provides a floor of protection on the amount of income that an annuitant may receive if he/she/they convert (s) the contract to an annuity.

Guaranteed Minimum Accumulation Benefit (GMAB): A living benefit that provides a base of protection on the contract value.

Guaranteed Minimum Withdrawal Benefit (GMWB): A living benefit that ensures the investor will receive a minimum amount of annual withdrawal from the contract over a stated number of years.

Payout Options:

Fixed Period: Payments are made for a fixed period of time.

Single Life: Payments are made for the lifetime of the annuitant.

Single Life with Period Certain: Payments are made for the longer of the lifetime of the annuitant or a fixed period.

Single Life with Full Refund: Payments are made for the lifetime of the annuitant; if the annuitant dies before the sum of payments is at least equal to the principal amount annuitized, the difference is paid out to the beneficiary in a lump sum.

Joint and Survivor with Period Certain: Payments are made for the longer of the lifetime of the annuitant, the lifetime of the joint annuitant, or a fixed period. This option may include a reduction in the payment amount to the joint annuitant if the annuitant dies first.

Joint and Survivor: Payments are made for the lifetime of the annuitant or joint annuitant. This option may include a reduction in the payment amount to the joint annuitant if the annuitant dies first.

Policy Ratings are provided by third-party organizations as a depiction of the financial strength of the insurance company.

Financial strength is an important consideration for an investor especially with regard to death benefits, living benefits, and annuity protections offered by the contract.

Rating Organization: A.M. Best Rating Definition

A++, A+ Superior ability to meet ongoing obligations A, A- Excellent ability to meet ongoing obligations B++, B+ Very good ability to meet ongoing obligations B, B- Fair ability to meet ongoing obligations C++, C+ Marginal ability to meet ongoing obligations C, C- Weak ability to meet ongoing obligations D Poor ability to meet ongoing obligations E Under regulatory supervision F In liquidation

S Rating has been suspending due to sudden, significant events impacting ability to meet ongoing obligation, but for which rating implications can not yet be evaluated.

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Premium Types include either flexible or single for variable annuities.

Subaccount Expenses

Average subaccount total expense: The arithmetic average of the total subaccount expenses for all subaccounts.

Highest total subaccount expense: The total expense ratio for the subaccount with the highest total expenses offered in the VA contract.

Median total subaccount expense: The total expense ratio for the subaccount with the expense ratio in the middle of the subaccount lineup; i.e., lining up all of the total expense ratios for all subaccounts, this is the total expense ratio halfway from the top and bottom.

Lowest total subaccount expense: The total expense ratio for the subaccount with the lowest total expenses offered in the VA contract.

Variable AIR % is the assumed interest rate available at the point of annuitizing a contract using a variable annuity option. The assumed interest rate contributes to the amount of initial payout and the volatility of that payout based on market conditions.

Investment Options

Current 7-day yield is a yield quotation based on the seven days ended on the date of the most recent balance sheet of the Registrant included in the registrant statement. It is computed by determining the net change (exclusive of capital change and income other than investment income) in the value of the hypothetical pre-existing account having a balance of one accumulation unit of the account or subaccount at the beginning of the period, subtracting a hypothetical charge reflecting deductions from contract owner accounts, and dividing the difference by the value of the account at the beginning of the base period to obtain the base period return. The base period return is then multiplied by (365/7), with the resulting yield figure carried to at least the nearest hundredth of one percent. The current 7-day yield more closely reflects the current earnings of the money-market subaccount than the total return calculation.

Morningstar does not calculate the current yield, but instead collects it from surveys that we conduct.

DCA Fixed Account is a fixed account specifically designated as being available as the source of dollar cost averaging.

Maximum Back Load % appears in the standardized returns section of the report and is the maximum deferred charge that an investor could be charged when withdrawing dollars from the policy.

Maximum Front Load % appears in the standardized returns section of the report and is the maximum front load for the policy that an investor could be charged.

The Morningstar Style Box reveals a fund's investment strategy. For equity subaccounts and fixed-income subaccounts respectively, the vertical axis shows the market capitalization of the stocks owned or the average credit quality of the bonds owned, and the horizontal

Management Fees

12-B1 fee is the maximum annual charge deducted from fund assets to pay for distribution and marketing costs. This information is taken directly from the fund’s prospectus.

Morningstar Rating is calculated for subaccounts with at least a three-year history. It is calculated based on a Morningstar Risk-Adjusted Return measure that accounts for variation in a subaccount’s monthly performance, placing more emphasis on downward variations and rewarding consistent performance. The top 10% of subaccounts in each category receive 5 stars, the next 22.5% receive 4 stars, the next 35% receive 3 stars, the next 22.5% receive 2 stars and the bottom 10% receive 1 star.

The Overall Morningstar Rating for a subaccount is derived from a weighted average of the performance figures associated with its three-, five- and 10-year (if applicable)

Morningstar Rating metrics. Please note that some Morningstar proprietary calculations, including the Morningstar Rating, are calculated based on adjusted historical returns.

If the extended performance rating is in effect, the “stars” are represented as unshaded stars. For each variable annuity subaccount whose underlying investment has at least a three-year history, Morningstar calculates a Morningstar Rating based on a Morningstar Risk-Adjusted Return measure that accounts for variation in a subaccount’s adjusted monthly performance, placing more emphasis on downward variations and rewarding consistent performance. The top 10% of subaccounts in each category receive 5 stars, the next 22.5% receive 4 stars, the next 35% receive 3 stars, the next 22.5% receive 2 stars and the bottom 10% receive 1 star. This investment’s independent Morningstar Rating metric is then compared against the variable annuity subaccount universe’s actual performance breakpoints to determine its extended performance rating.

The Overall Morningstar Rating for a variable annuity subaccount is derived from a weighted average of the actual performance figures associated with its three-, five- and 10-year (if applicable) Morningstar Rating metrics.

Performance

Standardized Returns, both monthly and quarterly, assume reinvestment of dividends and capital gains. It depicts performance without adjusting for the effects of taxation, but are adjusted to reflect expenses, including M&E risk charges, administration fees, fund-level expenses such as management fees and operating fees, and policy-level charges such as surrender, contract and sales charges. If adjusted for taxation, the performance quoted would be reduced. Standardized Returns are calculated in accordance with the rules outlined in SEC Rule 482, Forms N-3 and N-4, and reflect the investment experience from the inception date of the subaccount within the separate account.

Non-standardized returns illustrate performance that is adjusted to reflect recurring and non-recurring charges such as surrender fees, contract charges, maximum front-end load, maximum deferred load, maximum M&E risk charge, administrative fees and underlying fund-level expenses for various time periods. Non-standardized performance returns assume reinvestment of dividends and capital gains. If adjusted for the effects of taxation, the subaccount returns would be significantly reduced. The main differences between non-standardized returns and non-standardized returns is that non-non-standardized returns allow

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Pre-inception returns will be calculated for the subaccount.

These adjusted historical returns are based on the inception date of the oldest share class of the underlying fund. If a particular subaccount includes pre-inception returns, the return history will be italicized for any time periods prior to the inception date of the subaccount. These returns will be adjusted to reflect the same fees and expenses as referenced under the Standardized Total Return section above.

While the inclusion of pre-inception data provides valuable insight into the probable long-term behavior of a subaccount based on its underlying fund performance, investors should be aware that an adjusted historical return can only provide an approximation of that behavior. These adjusted historical returns are not actual returns. Calculation methodologies utilized by Morningstar may differ from those applied by other entities, including the subaccount itself.

Total Expense Ratio % is the expense ratio pulled from the variable annuity’s prospectus. This represents the percentage of a subaccount’s assets used to pay for operating expenses and management fees, including 12b-1, administrative and all other asset-based fess incurred by the subaccount, except brokerage commissions and sales charges. Please note, this is not an audited number.

Withdrawals may trigger a taxable event. A 10% IRS penalty may apply to withdrawals prior to age 59-1/2