Transamerica O-Share Variable Annuity

TRANSAMERICA VARIABLE ANNUITY O-SHARE

Transamerica Life Insurance Company

Separate Account VA B (EST. 1/19/1990)

Administrative Office

6400 C Street SW

Cedar Rapids, Iowa 52499-0001

(800)525-6205

www.transamerica.com

Transamerica Financial Life Insurance Company

Separate Account VA BNY (EST. 9/27/1994)

Administrative Office

6400 C Street SW

Cedar Rapids, Iowa 52499-0001

(800)525-6205

www.transamerica.com

Sales of this Policy were discontinued for new purchasers effective February 26, 2021.

This prospectus describes information You should know before You purchase a Transamerica Variable Annuity O-Share variable annuity. The prospectus describes a contract between each Owner and joint Owner (“You”) and Transamerica Life Insurance Company or Transamerica Financial Life Insurance Company (“us,” “we,” “our” or “Company” ). This is an individual, deferred, flexible premium variable annuity. This variable annuity allows You to allocate Your premium payments among the Fixed Account (if available) and the underlying fund portfolios.

This prospectus and the underlying fund prospectuses give You important information about the policies and the underlying fund portfolios. Please read them carefully before You invest and keep them for future reference.

The Securities and Exchange Commission has not approved or disapproved these securities, or passed upon the adequacy of this prospectus. Any representation to the contrary is a criminal offense.

This variable annuity may not be suitable for everyone. This variable annuity may not be appropriate for people who do not have a long-term investment time horizon and is not appropriate for people who intend to engage in market timing or other frequent (disruptive) trading. You will get no additional tax advantage from this variable annuity if You are investing in a variable annuity through a tax-advantaged retirement plan (such as a 401(k) plan or Individual Retirement Account (“IRA”)). This prospectus is not intended to provide tax, accounting or legal advice.

We are not an investment adviser nor are we registered as such with the SEC or any state securities regulatory authority. We are not acting in any fiduciary capacity with respect to Your Policy nor are we acting in any capacity on behalf of any tax-advantaged retirement plan. This information does not constitute personalized investment advice or financial planning advice.

Additional information about certain investment products, including variable annuities, has been prepared by the Securities and Exchange Commission’s staff and is available at Investor.gov.

Prospectus Date: May 1, 2024

glossary of terms

Accumulation Unit- An accounting unit of measure used in calculating the Policy Value in the Separate Account before the Annuity Commencement Date. For more information on unit values, including how they are calculated after the Annuity Commencement Date, please see the Statement of Additional Information.

Adjusted Policy Value- The Policy Value increased or decreased by any Excess Interest Adjustment.

Administrative Office- Transamerica Life Insurance Company and Transamerica Financial Life Insurance Company, Attention: Customer Care Group, 6400 C Street SW, Cedar Rapids, IA 52499, (800)525-6205.

Annuitant- The person on whose life any annuity payments involving life contingencies will be based.

Annuitize (Annuitization)- When You switch from the accumulation phase to the income phase and we begin to make annuity payments to You (or Your payee).

Annuity Commencement Date- The date upon which annuity payments are to commence. This date may not be later than the last day of the Policy month following the month in which the Annuitant attains age 99 (earlier if required by state law).

Annuity Payment Option- A method of receiving a stream of annuity payments selected by the Owner.

Assumed Investment Return or AIR- The annual effective rate shown in Your Policy that is used in the calculation of each variable annuity payment.

Business Day- A day when the New York Stock Exchange is open for regular trading. Business Day may be referred to as Market Day in Your Policy.

Cash Value- The Adjusted Policy Value less any applicable surrender charge. If You are surrendering your Policy, annuitizing Your Policy or receiving a death benefit, You will receive the state minimum required Cash Value if greater than Your Cash Value.

Code- The Internal Revenue Code of 1986, as amended.

Death Proceeds- The amount payable upon death.

Excess Interest Adjustment- A positive or negative adjustment to amounts paid out or transferred from the Fixed Account Guaranteed Period Options prior to the end of the guaranteed period. The adjustment reflects changes in the interest rates declared by us since the date any payment was received by, or an amount was transferred to, the Guaranteed Period Option. The Excess Interest Adjustment can either decrease or increase the amount to be received by the Owner upon withdrawals, surrenders or commencement of annuity payments, depending upon whether there has been an increase or decrease in interest rates, respectively. The Excess Interest Adjustment will not decrease the interest credited to Your Policy below the guaranteed minimum. The Excess Interest Adjustment does not apply to policies issued in New York by Transamerica Financial Life Insurance Company.

Fixed Account- One or more Investment Options under the Policy that are part of our general assets and are not in the Separate Account.

Fund Facilitation Fee- A fee we charge in order to make certain Portfolio Companies available as Investment Options under the Policy. This may also be referred to as a Platform Charge.

Guaranteed Lifetime Withdrawal Benefit- Any optional benefit under the Policy that provides a guaranteed minimum withdrawal benefit, including the Retirement Income Max® 2.0 rider, the Retirement Income Choice® 2.0 rider and the Transamerica Income EdgeSM rider.

Guaranteed Period Options- The various guaranteed interest rate periods of the Fixed Account which we may offer and into which premium payments may be paid or amounts transferred when available.

Investment Option(s) - The Subaccounts and the Fixed Account.

Investment Restrictions - The requirement of the Owners to invest in certain underlying fund portfolios, as required by certain optional riders.

Owner (You, Your)- The person who may exercise all rights and privileges under the Policy.

Physician- A doctor of medicine or osteopathy as set forth in Section 186 (r)(1) of the Social Security Act, as amended, who is legally authorized to practice medicine and surgery within the United States by the jurisdiction in which he or she performs such function or action.

Policy- The Transamerica Variable Annuity O-Share, an individual deferred, flexible premium variable annuity. Also referred to as the contract.

Policy Date- The date shown on the Policy data page attached to the Policy and the date on which the Policy becomes effective.

Policy Value- On or before the Annuity Commencement Date, the Policy Value is equal to the Owner's:

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premium payments; minus

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gross withdrawals (withdrawals plus the surrender charge on the portion of the requested withdrawal that is subject to the surrender charge plus or minus any Excess Interest Adjustment plus taxes (on the withdrawal)); plus

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interest credited in the Fixed Account; plus

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accumulated gains in the Separate Account; minus

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accumulated losses in the Separate Account; minus

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service charges, Premium Based Charges, rider fees, premium taxes, transfer fees, and other charges (including those imposed upon termination), if any.

Policy Year- A Policy Year begins on the Policy Date and on each anniversary thereafter.

Portfolio Company(ies)- The investment company(ies) made available as Investment Options under the Policy. Also referred to as underlying fund portfolios.

Premium Based Charge - The sum of all charges for a premium payment previously calculated and collected as part of the quarterly Premium Based Charge. The total Premium Based Charge includes Surrender Charges imposed due to partial withdrawals and full surrenders.

Separate Account- Separate Account VA B and Separate Account VA BNY, Separate Accounts established and registered as unit investment trusts under the Investment Company Act of 1940, as amended (the “1940 Act”), to which premium payments under the policies may be allocated.

Separate Account Value- The portion of the Policy Value that is invested in the Separate Account.

Stable Account- A Fixed Account option, only available if You elect the Transamerica Income EdgeSM rider, to which You must allocate a portion of Your premium payments and Policy Value. Assets in the Stable Account are not subject to Separate Account Annual Expenses as set forth under ANNUITY POLICY FEE TABLE AND EXPENSE EXAMPLES.

Subaccount- A subdivision within the Separate Account, the assets of which are invested in a specified underlying fund portfolio.

Surrender Charge - The Surrender Charge is an acceleration of some or all of the remaining Premium Based Charges. For a surrender, the Surrender Charge is equal to any remaining Premium Based Charge. If a withdrawal is made in excess of the Surrender Charge Free Amount, a portion of the remaining Premium Based Charge will be deducted from the Policy Value at that time.

Surrender Charge Free Amount- The amount that can be withdrawn each Policy Year without incurring any Surrender Charges. Please see EXPENSES – Surrender Charges for more explanation.

Valuation Period- The period of time from one determination of Accumulation Unit values and annuity unit values to the next subsequent determination of those values. Such determination shall be made generally at the close of business on each Business Day.

Written Notice- Written Notice, signed by the Owner, that gives us the information we require and is received in good order at the Administrative Office. For some transactions, we may accept an electronic notice or telephone instructions. Such electronic notice must meet the requirements for good order that we establish for such notices.

important INFORMATION you should consider about the policy

	FEES AND EXPENSES	Location in Prospectus
Charges for Early Withdrawal	If You withdraw money in excess of the Surrender Charge Free Amount, You may be assessed a surrender charge on the withdrawal. The current surrender charge, if any is imposed, applies to each premium payment. The surrender charge is an acceleration of some or all of the remaining premium based charge. The total of Premium Based Charges and surrender charges deducted will not exceed 5% of the aggregate premium payments. There are no surrender charges for any particular premium payment after seven years.	Annuity Policy Fee Tables and Expense Examples Transaction Expenses – Surrender Charge Access to Your Money Surrenders and Withdrawals
Transaction Charges	In addition to surrender charges, You also may be assessed a transfer fee and special services fee. Transfer Fee. We reserve the right to charge for transfers among Investment Options after the first 12 transfers per Policy Year. For each such additional transfer, we may impose a transfer fee of $10. Currently, we do not charge a transfer fee, but reserve the right to do so. Special Service Fee. We reserve the right to deduct a charge for special services, including overnight delivery, duplicate policies, handling insufficient checks on new business, duplicate Form 1099 and Form 5498 tax forms, check copies, printing and mailing previously submitted forms, and asset verification requests from mortgage companies. For policies issued prior to May 1, 2015, the special services fee may be up to $30.	Annuity Policy Fee Tables and Expense Examples Expenses – Transaction Expenses

	FEES AND EXPENSES			Location in Prospectus
Ongoing Fees and Expenses (annual charges)	The table below describes the fees and expenses that You may pay each year, depending on the options You choose. Please refer to Your Policy specifications page for information about the specific fees You will pay each year based on the options You have elected.			Annuity Policy Fee Tables and Expense Examples Base Contract Expenses Appendix – Portfolio Companies Available Under the Policy
	Annual Fee	Minimum	Maximum
	Base Policy1	0.75%	2.75%
	Premium Based Charge2	1.25%	5.00%
	Portfolio Company (fund fees and expenses)3	0.54%	1.45%
	Optional Benefit Expenses (if elected)	0.15%1	2.50%4
	1 As a percentage of average Separate Account Value.
	2 As a percentage of premium payments.
	4 As a percentage of Portfolio Company assets.
	5 As a percentage of the withdrawal base.
	Because Your Policy is customizable, the choices You make affect how much You will pay. To help You understand the cost of owning Your Policy, the following table shows the lowest and highest cost You could pay each year based on current charges. This estimate assumes that You do not take withdrawals from the Policy, which could add surrender charges that substantially increase costs.
	Lowest Annual Cost $2,038	Highest Annual Cost $5,774
	Assumes:	Assumes:
	●Investment of $100,000 ●5% annual appreciation ●Least expensive Portfolio Company fees and expenses ●No optional benefits ●No sales charges ●No additional purchase payments, transfers, or withdrawals	●Investment of $100,000 ●5% annual appreciation ●Most expensive combination of optional benefits and Portfolio Company fees and expenses ●No sales charges ●No additional purchase payments, transfers, or withdrawals
	RISKS			Location in Prospectus
Risk of Loss	You can lose money by investing in this Policy.			Principal Risks of Investing in the Policy
Not a Short-Term Investment	This Policy is not a short-term investment and is not appropriate for an investor who needs ready access to cash. Surrender charges may apply for several years under the Policy. Surrender charges will reduce the value of Your Policy if You withdraw money during that time. The benefits of tax deferral and living benefit protection also means the Policy is more beneficial to investors with a long-term time horizon.			Principal Risks of Investing in the Policy Transaction Expenses - Surrender Charges Tax Information

	RISKS	Location in Prospectus
Risks Associated with Investment Options	●An investment in this Policy is subject to the risk of poor investment performance and can vary depending on the performance of the Investment Options available under the Policy. ●Each Investment Option, including the Fixed Account, has its own unique risks. ●You should review the prospectuses for the available Portfolio Companies before making an investment decision.	Principal Risks of Investing in the Policy Investment Options Appendix: Portfolio Companies Available Under the Policy
Insurance Company Risks	Any obligations (including under the Fixed Account), guarantees, and benefits under the Policy are subject to our claims-paying ability. If we experience financial distress, we may not be able to meet our obligations to You. More information about Transamerica Life Insurance Company or Transamerica Financial Life Insurance Company, including our financial strength ratings, is available by visiting transamerica.com or by calling toll-free (800)525-6205.	Principal Risks of Investing in the Policy Information About Us Financial Condition
	RESTRICTIONS	Location in Prospectus
Investments	●We reserve the right to impose a charge for transfers in excess of 12 transfers per Policy Year. ●We reserve the right to limit transfers in circumstances of large or frequent transfers. ●The Fixed Account option may not be available for investment depending on when You applied for Your Policy and when it was issued. ●We reserve the right to remove or substitute the Portfolio Companies that are available as Investment Options under the Policy.	Transaction Expenses Investment Option – Transfers Market Timing and Disruptive Trading
Optional Benefits	●Certain optional benefits limit or restrict the Investment Options that You may select under the Policy. We reserve the right to change these restrictions in the future. ●Withdrawals may reduce the value of an optional benefit by an amount greater than the value withdrawn, which could significantly reduce the value or even terminate the benefit. ●We reserve the right to stop offering an optional benefit at any time for new sales, which includes sales to the Owners who may want to purchase the benefit after they purchase the Policy. ●In some cases, a benefit may not be available through all financial intermediaries or all states. For more information on the options available for electing a benefit, please contact Your financial intermediary or our Administrative Office.	Investment Restrictions Benefits Available Under the Policy Optional Benefit Riders

	TAXES	Location in Prospectus
Tax Implications	●Consult with a tax professional to determine the tax implications of an investment in and payments received under the Policy. ●If You purchase the Policy as an individual retirement account or through a tax qualified plan, You do not get any additional tax benefit. ●You will generally not be taxed on increases in the value of Your Policy until they are withdrawn. Earnings on Your Policy are taxed at ordinary income tax rates when withdrawn, and You may have to pay a penalty if You take a withdrawal before age 59 ½.	Tax Information
	CONFLICT OF INTEREST	Location in Prospectus
Investment Professional Compensation	Your investment professional may receive compensation for selling this Policy to You, in the form of commissions, additional cash benefits (e.g., bonuses), and non-cash compensation. Our affiliate, Transamerica Capital, Inc. (“TCI”) is the principal underwriter and may share the revenue we earn on this Policy with Your investment professional’s firm. In addition, we may pay all or a portion of the cost of affiliates’ operating and other expenses. This conflict of interest may influence Your investment professional to recommend this Policy over another investment for which the investment professional is not compensated or compensated less.	Distribution of the Policies
Exchanges	If You already own an insurance Policy, some investment professionals may have a financial incentive to offer You a new Policy in place of the one You own. You should only exchange a Policy You already own if You determine, after comparing the features, fees, and risks of both policies, that it is better for You to purchase the new Policy rather than continue to own Your existing Policy.	Exchanges and/or Reinstatements

Overview of the policy

Purpose

The Transamerica Variable Annuity O-Share is a variable annuity Policy. You can use the Policy to accumulate assets for retirement or other long-term financial planning purposes. The amount of money You are able to accumulate in Your Policy depends upon the performance of Your Investment Options. The Policy also offers a death benefit to protect Your designated beneficiaries.

This Policy may not be appropriate for people who do not have a long-term investment time horizon and is not appropriate for people who intend to engage in market timing or other frequent (disruptive) trading.

Who the Policy is Appropriate For

The Policy is designed for investors who intend to accumulate assets for retirement or other long-term financial planning best suited for those with a long-term investment horizon. Although You have the ability to make partial withdrawals and/or surrender the Policy at any time during the accumulation phase, the Policy should not be viewed as a highly liquid investment. In that regard, withdrawals taken in the near term can result in Your being assessed a surrender charge, which can be a significant amount. In addition, if You participate in certain optional benefits, withdrawals can markedly reduce the benefit’s value. Finally, failure to hold the Policy for the long-term would mean that You lose the opportunity for the performance of Your chosen Investment Options to grow on a tax-deferred basis. Thus, the Policy’s features are appropriate for an investor who does not have significant liquidity needs with respect to money dedicated to the Policy, has a long-term investment horizon, and has purchased the Policy for retirement purposes or other long-term financial planning purposes.

Phases of the Policy

The Policy has two phases: (1) an accumulation (or savings) phase and (2) and annuity (or income) phase.

Accumulation Phase. To help You accumulate assets during the accumulation phase, You can invest Your Premium payments and Policy Value in:

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Underlying fund portfolios available under the Policy, each of which has its own investment strategies and risks; investment adviser(s); expense ratio; and performance history; and

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The Fixed Account option, which offers a guaranteed interest rate during a selected period.

A list of Portfolio Companies in which You can invest is provided in an Appendix to this Prospectus. See Appendix - Portfolio Companies Available Under the Policy.

Annuity Phase. You can elect to Annuitize Your Policy and turn Your Policy Value into a stream of income payments called annuity payments. When You Annuitize Your Policy, the accumulation phase ends, and You will no longer be able to withdraw money from Your Policy. Any guaranteed benefits You elected will terminate without value.

You can choose from among several Annuity Payment Options, including those guaranteeing payments for life and/or for a fixed time period. If You choose income for a specified period, life income with 10 years certain, life income with guaranteed return of Policy proceeds, or income of a specified amount, and the person receiving annuity payments dies prior to the end of the guaranteed period, then the remaining guaranteed annuity payments will be continued to a new payee, or their present value may be paid in a single sum.

Primary Features and Options of the Policy

Type of Policy. Transamerica Variable Annuity O-Share Policy is a flexible premium deferred variable annuity Policy. It is a “deferred” annuity because You defer taking annuity payments during the accumulation phase. It is a “flexible premium” annuity because You are generally not required to make any premium payments in addition to the initial minimum premium payment. The Policy is “variable” because its value can go up or down based on the performance of the Investment Options You choose. The Policy is available as a non-qualified or qualified Policy. The tax treatment of Your Policy may impact the benefits, as well as fees and charges under Your Policy.

Accessing Your Money. Before You Annuitize, You can withdraw money from Your Policy at any time. If You take a withdrawal, You may be subject to a negative Excess Interest Adjustment and/or have to pay a surrender charge and/or income taxes, including a tax penalty if You are younger than age 59½.

Tax Treatment. You can transfer money between Investment Options without tax implications, and earnings (if any) on Your investments are generally tax-deferred. You are taxed only upon: (1) making a withdrawal; (2) receiving a payment from us; or (3) payment of a death benefit.

Death Benefits. The Policy includes, at no additional cost, a default death benefit that will pay Your designated beneficiaries at least the Policy Value. You can purchase a guaranteed minimum death benefit for an additional fee, which may increase the amount of money payable to Your designated beneficiaries upon Your death.

Optional Living Benefits. For an additional fee, You may have purchased one of several Guaranteed Lifetime Withdrawal Benefits, which are designed to provide a guaranteed level of withdrawals from Your Policy, regardless of investment performance.

Additional Services. At no additional charge, You may select the following additional services:

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Dollar-Cost Averaging. This service allows You to automatically transfer amounts between certain Investment Options on a monthly basis.

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Asset Rebalancing. This service automatically reallocates Your Policy Value among Your Investment Options on a periodic basis to maintain Your standing allocation instructions.

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Systematic Payout Options. This service allows You to receive regular automatic withdrawals from Your Policy either on a monthly, quarterly, semi-annual and annual basis.

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Telephone and Electronic Transactions. This service allows You to make certain transactions by telephone or other electronic means with the appropriate authorization from You.

ANNUITY POLICY FEE TABLE AND EXPENSE EXAMPLES

The following table describes the fees and expenses that You will pay when buying, owning, and surrendering or making withdrawals from the Policy. Please refer to Your Policy specification page for information about the specific fees You will pay each year based on the options You have elected.

The first table describes the fees and expenses that You will pay at the time that You buy the Policy, surrender or make withdrawals from the Policy, or transfer Cash Value between Investment Options. State premium taxes may also be deducted.

Transaction Expenses:

Sales Load Imposed On Premium Payments	0%
Maximum Surrender Charge(1)	5%
Maximum Transfer Fee(2)	$10
Maximum Special Service Fee(3)	$50*

* $0 - $30 for policies issued prior to May 1, 2015.

The next table describes the fees and expenses that you will pay each year during the time that you own the Policy, not including portfolio fees and expenses.

Annual Contract Expenses:

Maximum Annual Service Charge(4)	$50
Maximum Premium Based Charge(5)	5%
Base Contract Expenses (as a percentage, annually, of average Separate Account Value)(6):	0.75%
Fund Facilitation Fee (as a percentage, annually, of the net asset value of Subaccount)	0.30%
Optional Benefit Expenses:
Annual Step-Up Death Benefit (as a percentage, annually, of average Separate Account Value)	0.35%
Return of Premium Death Benefit (as a percentage, annually, of average Separate Account Value)	0.15%
Optional Death Benefit Riders – No Longer Available
Additional Death DistributionSM (annual charge - % of Policy Value)	0.25%
Additional Death Distribution+SM (annual charge - % of Policy Value)	0.55%

Maximum Fees

	Maximum
Optional Guaranteed Lifetime Withdrawal Benefit Rider Charges – No Longer Available(7)
Retirement Income Max® 2.0 rider (annual charge - % of Withdrawal Base)* (for riders issued on or after May 1, 2017)	2.50%
Retirement Income Choice® 2.0 rider (annual charge - % of Withdrawal Base) (for riders issued on or after May 1, 2017)
Base Benefit Designated Allocation Group A*	2.50%
Base Benefit Designated Allocation Group B*	2.50%
Base Benefit Designated Allocation Group C*	2.50%
Transamerica Income EdgeSM rider (annual charge - % of Withdrawal Base)* (for riders issued on or after May 1, 2017)	2.50%

*The Current rider fee will be less than or equal to the stated Maximum. Your rider fee may increase (or decrease) at the time of any automatic step-up. See Automatic Step-Up discussion for each applicable optional benefit. Your rider fee percentage will not exceed the maximum fee percentage shown in this table. The current rider fee will be disclosed in a Rate Sheet Prospectus Supplement. All Rate Sheet Prospectus Supplements are also available on the EDGAR system at sec.gov (File Numbers 333-189435 for TLIC and 333-189436 for TFLIC).

Maximum Fee and Current Fee:

	Maximum	Current
Optional Guaranteed Lifetime Withdrawal Benefit Riders – No Longer Available
Retirement Income Max® 2.0 rider (annual charge - % of Withdrawal Base) (for riders issued May 1, 2015 to April 30, 2017)	2.00%	1.25%
Retirement Income Choice® 2.0 rider (annual charge - % of Withdrawal Base) (for riders issued May 1, 2015 to April 30, 2017)
Base Benefit Designated Allocation Group A	2.20%	1.45%
Base Benefit Designated Allocation Group B	1.85%	1.10%
Base Benefit Designated Allocation Group C	1.45%	0.70%
Transamerica Income EdgeSM rider (annual charge - % of Withdrawal Base)* (for riders issued on or after May 1, 2017)	2.15%	1.40%

	Maximum	Current
Optional Guaranteed Lifetime Withdrawal Benefit Riders – No Longer Available:
Retirement Income Max® rider (annual charge - % of Withdrawal Base)	2.00%	1.25%
Retirement Income Choice® 1.6 rider (annual charge - % of Withdrawal Base) (for riders issued on or after May 1, 2014)
Base Benefit Designated Allocation Group A	2.20%	1.45%
Base Benefit Designated Allocation Group B	1.85%	1.10%
Base Benefit Designated Allocation Group C	1.45%	0.70%
Additional Benefits available with Retirement Income Choice® 1.6 rider:
Income EnhancementSM - (Single Life Option)	0.30%	0.30%
Income EnhancementSM - (Joint Life Option)	0.50%	0.50%
Retirement Income Choice® 1.6 rider (annual charge - % of Withdrawal Base) (for riders issued prior to May 1, 2014)
Base Benefit Designated Allocation Group A	2.30%	1.55%
Base Benefit Designated Allocation Group B	1.85%	1.10%
Base Benefit Designated Allocation Group C	1.45%	0.70%
Additional Benefits available with Retirement Income Choice® 1.6 rider:
Income EnhancementSM - (Single Life Option)	0.30%	0.30%
Income EnhancementSM - (Joint Life Option)	0.50%	0.50%

Notes to Fee Table

Transaction Expenses:

1) Maximum Surrender Charge:

The Surrender Charge, if any is imposed, applies to each premium payment, regardless of how Policy Value is allocated among the Investment Options. The total of Premium Based Charges and Surrender Charges deducted will not exceed 5% of the aggregate premium payments.

2) Transfer Fee:

The transfer fee, if any is imposed, applies to each Policy, regardless of how Policy Value is allocated among the Investment Options. There is no fee for the first 12 transfers per Policy Year. For additional transfers, we may charge a fee of $10 per transfer. Currently, we do not charge a transfer fee, but reserve the right to do so.

3) Special Service Fees:

We may deduct a charge for special services, including overnight delivery and duplicate policies. We reserve the right to deduct a charge for special services in the future, including non-sufficient checks on new business; duplicate Form 1099 and Form 5498 tax forms; check copies; printing and mailing previously submitted forms; and asset verification requests from mortgage companies. We may charge a fee for each service performed and fees may vary based on the type of service but will not exceed the maximum Special Service Fee shown above.

4) Annual Service Charge:

The annual service charge is assessed on each Policy anniversary and at the time of surrender. The maximum annual service charge is the lesser of $50 per Policy or 2% of the Policy Value.

Criteria for Potential Waiver	Potential Waiver Amount**
$50,000 thru $249,999.99*	up to $35
$250,000 or more*	up to $50

Based on the greater of Policy Value or sum of all premium payments less all withdrawals.

In no event will we waive in the aggregate more than the actual annual service charge for any Policy Year.

Annual Contract Expenses:

5) Premium Based Charge:

Premium Based Charge (as a percentage of premium payments)
Premium Payments	Total Charges
$0 thru $49,999.99	5.00%
$50,000.00 thru $99,999.99	4.50%
$100,000.00 thru $249,999.99	3.50%
$250,000.00 thru $499,999.99	2.50%
$500,000.00 thru $999,999.99	2.00%
$1,000,000.00 or more	1.25%

Each premium payment has its own Premium Based Charge. The total Premium Based Charge for each premium payment is payable in quarterly installments over seven years. The charge reflected is the maximum and the Premium Based Charge may decrease as total premium payments increase. If You surrender Your Policy, the total remaining Premium Based Charge (if any) will be deducted. If You make a withdrawal which is greater than the Surrender Charge Free Amount, a portion of the remaining Premium Based Charge will be deducted.

6) Base Contract Expenses:

Base contract expenses consist of the Mortality & Expense Risk Fee and the Administrative Fee.

Mortality and Expense Risk and Administrative Fee: The mortality and expense risk fee shown is for the accumulation phase with the base death benefit. During the income phase, the mortality and expense risk and administrative fee is at an annual rate of 1.25%.

Fund Facilitation Fee: This daily fee is applied only to Policy Value in the Subaccounts invested in the following Portfolio Companies:

Portfolio Companies	Annualized Fee %
American Funds - Asset Allocation FundSM - Class 2 American Funds - The Bond Fund of AmericaSM - Class 2 American Funds - Growth FundSM - Class 2 American Funds - Growth-Income FundSM - Class 2 American Funds - International FundSM - Class 2	0.30%
AB Balanced Hedged Allocation Portfolio - Class B State Street Total Return V.I.S. Fund - Class 3	0.20%
TA MSCI EAFE Index - Service Class TA S&P 500 Index - Service Class	0.15%

We charge a Fund Facilitation Fee in order to make certain Portfolio Companies available as investment choices under the policies. We apply the fee to Portfolio Companies that invest in underlying fund portfolios that do not provide us with the amount of revenue we require in order for us to meet our expenses and revenue targets. This fee is assessed daily based on the net asset value of Portfolio Companies that we specify.

Optional Benefit Separate Account Expenses: Any optional Separate Account expense is in addition to the mortality and expense risk and administrative fees.

OPTIONAL RIDERS

In some cases, riders to the Policy are available that provide optional benefits. There are additional fees (annualized fee charged quarterly) for those riders.

7) Optional Guaranteed Lifetime Withdrawal Benefit Riders – No Longer Available:

Retirement Income Max® 2.0 Rider and Retirement Income Choice® 2.0 Rider - Withdrawal Base: We use the withdrawal base to calculate the rider fee and the rider withdrawal amount. The withdrawal base on the rider date is the Policy Value.

Transamerica Income EdgeSM Rider - Withdrawal Base: We use the withdrawal base to calculate the rider withdrawal amount and the rider fee. The withdrawal base on the rider date is the Policy Value. For riders issued prior to the date of this prospectus, the withdrawal percentage and growth rate percentage information can be found in the Statement of Additional Information “Appendix - Prior Withdrawal and Growth Percentages”.

Retirement Income Max® Rider and Retirement Income Choice® 1.6 Rider - Withdrawal Base: We use the withdrawal base to calculate the rider fee and the rider withdrawal amount. The withdrawal base on the rider date is the Policy Value. For riders issued prior to the date of this prospectus, the withdrawal percentage, growth percentage and fee information can be found in the Statement of Additional Information “Appendix - Prior Withdrawal/Growth Percentages and Rider Fees”.

Annual Portfolio Company Expenses:

The next section shows the minimum and maximum total operating expenses charged by the Portfolio Companies that You may pay periodically during the time You own the Policy. A complete list of the Portfolios available under the Policy, including their annual expenses may be found under Appendix - Portfolio Companies Available Under the Policy.

Annual Portfolio Company Expenses	Minimum	Maximum
Expenses that are deducted from Portfolio Company assets, including management fees, distribution and/or service 12b-1 fees, Fund Facilitation Fee if applicable and other expenses	0.54%	1.45%
Expenses that are deducted from Portfolio Company asset, including management fees, 12b-1 fees, Fund Facilitation Fee if applicable and other expenses, after any waivers or expense reimbursement	0.54%	1.41%

Expense Examples(1):

The following Examples are intended to help You compare the cost of investing in the Policy with the cost of investing in other variable annuity policies. These costs include Owner transaction expenses, annual Policy expenses, and annual Portfolio Company operating expenses.

The Examples assume that you invest $100,000 in the Policy for the time periods indicated. The Examples also assume that Your Policy has a 5% return each year and assumes the most expensive combination of annual Portfolio Company expenses and optional benefits available for an additional charge. This includes the maximum annual Portfolio Company expenses (including Fund Facilitation Fee, if applicable) Annual Step-Up Death Benefit, Additional Death Distribution+SM rider and Retirement Income Choice® 2.0 rider. Although your actual costs may be higher or lower, based on these assumptions, Your costs would be:

If the Policy is surrendered at the end of the applicable time period:

1 Year	$10,600
3 Years	$22,044
5 Years	$33,824
10 Years	$64,923

Principal Risks of Investing in the Policy

There are risks associated with investing in the Policy. You can lose money in a variable annuity, including potential loss of Your original investment. The value of Your investment and any returns will depend primarily on the performance of the underlying fund portfolios You select. Each underlying fund portfolio may have its own unique risks.

Variable annuities are not a short-term investment vehicle. The surrender charge applies for a number of years, so that the Policy should only be purchased for the long-term. Under some circumstances, You may receive less than the sum of Your premium payments. In addition, full or partial withdrawals will be subject to income tax and may be subject to a 10% Internal Revenue Service (“IRS”) penalty if taken before age 59½. Accordingly, You should carefully consider Your income and liquidity needs before purchasing a Policy. Additional information about these risks appears in the Tax Information section of this prospectus.

Risks Of An Increase In Current Fees And Expenses. Certain fees and expenses are currently assessed at less than their guaranteed maximum levels. In the future, these charges may be increased up to the guaranteed (maximum) levels.

Investment Risk. You bear the risk of any decline in the Policy Value caused by the performance of the underlying fund portfolios held by the Subaccounts. Those funds could decline in value very significantly, and there is a risk of loss of your entire amount invested. The risk of loss varies with each underlying fund. This risk could have a significant negative impact on the value of certain optional benefits offered under the Policy. The investment risks are described in the prospectuses for the underlying funds.

Investment Restrictions – Opportunity Risks. Generally, the living benefit riders offered under the Policy restrict Your choice of available underlying fund portfolios. These restrictions are intended to protect us financially, in that they reduce the likelihood that we will have to pay guaranteed benefits under the riders from our own assets. These restrictions could result in an opportunity cost – in the form of underlying fund portfolios that You did not invest in that ultimately generated superior investment performance. Thus, You should consider these underlying fund portfolio restrictions when deciding whether to elect an optional benefit that features such restrictions.

Risk Associated With Election of Optional Benefits. Several of the optional benefits include a host of requirements that must be adhered to in order to preserve and maximize the guarantees we offer under the benefit. If You fail to adhere to these requirements, that may diminish the value of the benefit and even possibly cause termination of the benefit. In addition, it is possible that You will pay fees for the optional benefit without fully realizing the guarantees available under the optional benefit. For example, such would be the case if You were to hold a Guaranteed Lifetime Withdrawal Benefit for many years yet die sooner than anticipated, without having taken a significant number of lifetime withdrawals.

Risks of Managing General Account Assets. The general account assets of the Company are used to support the payment of guaranteed benefits under the Policy. To the extent that the Company is required to pay amounts in addition to the Policy Value, such amounts will come from our general account assets. You should be aware that the general account assets are exposed to the risks normally associated with a portfolio of fixed-income securities, including interest rate, option, liquidity and credit risk, and are also subject to the claims of the Company’s general creditors. The Company’s financial statements contained in the Statement of Additional Information include a further discussion of risks inherent in the general account investments.

Insurance Company Insolvency. It is possible that we could experience financial difficulty in the future and even become insolvent, and therefore unable to provide all of the guarantees and benefits that exceed the assets in the Separate Account that we promise.

Tax Consequences. Withdrawals are generally taxable to the extent of any earnings in the Policy, and prior to age 59½ a tax penalty may apply. In addition, even if the Policy is held for years before any withdrawal is made, withdrawals are taxable as ordinary income rather than capital gains.

Cybersecurity and Certain Business Continuity Risks

Our operations support complex transactions and are highly dependent on the proper functioning of information technology and communication systems. Any failure of or gap in the systems and processes necessary to support complex transactions and avoid systems failure, fraud, information security failures, processing errors, cyber intrusion, loss of data and breaches of regulation may lead to a materially adverse effect on our results of operations and corporate reputation. In addition, we must commit significant resources to maintain and enhance its existing systems in order to keep pace with applicable regulatory requirements, industry standards and customer preferences. If we fail to maintain secure and well-functioning information systems, we may not be able to rely on information for product pricing, compliance obligations, risk management and underwriting decisions. In addition, we cannot assure investors or consumers that interruptions, failures or breaches in security of these processes and systems will not occur, or if they do occur, that they can be timely detected and remediated. The occurrence of any of these events may have a materially adverse effect on our businesses, results of operations and financial condition.

For additional detail regarding cybersecurity and related risks, please reference the Cyber Security section in the Statement of Additional Information.

Business Continuity

Our business operations may be adversely affected by volatile natural and man-made disasters, including (but not limited to) hurricanes, earthquakes, terrorism, civil unrest, geopolitical disputes, military action, fires and explosions, pandemic diseases, and other catastrophes (“Catastrophic Events”). Over the past several years, changing weather patterns and climatic conditions have added to the unpredictability and frequency of natural disasters in certain parts of the world. To date, the COVID-19 pandemic has caused significant uncertainty and disruption to governments, business operations, and consumer behavior on a global scale. Such uncertainty as to future trends and exposure may lead to financial losses to our businesses. Furthermore, Catastrophic Events may disrupt our operations and result in the loss of, or restricted access to, property and information about Transamerica and its clients. Such events may also impact the availability and capacity of our key personnel. If our business continuity plans do not include effective contingencies for Catastrophic Events, we may experience business disruption, damage to corporate reputation, and damage to financial condition for a prolonged period of time.

Transamerica life insurance company, transamerica financial life insurance company, The separate account, and portfolio companies

Information About Us

Transamerica Life Insurance Company and Transamerica Financial Life Insurance Company, located at 6400 C Street SW, Cedar Rapids, Iowa 52499, is the insurance company issuing the Policy.

We are engaged in the sale of life insurance and annuity policies. Transamerica Life Insurance Company was incorporated under the laws of the State of Iowa on April 19, 1961 as NN Investors Life Insurance Company Inc., and is licensed in the District of Columbia, Guam, Puerto Rico, and the U.S. Virgin Islands and all states except New York. Transamerica Financial Life Insurance Company was incorporated under the laws of the State of New York on October 3, 1947 as Zurich Life Insurance Company and is licensed in all states and the District of Columbia. We are a wholly-owned indirect subsidiary of Transamerica Corporation which conducts most of its operations through subsidiary companies engaged in the insurance business or in providing non-insurance financial services. All of the stock of Transamerica Corporation is indirectly owned by Aegon Ltd., the securities of which are publicly traded. Aegon Ltd., a holding company, conducts its business through subsidiary companies engaged primarily in the insurance business.

All obligations arising under the policies, including the promise to make annuity payments, and payment of any amounts held in the Fixed Account are general corporate obligations of ours and subject to our claims paying ability. Accordingly, no financial institution, brokerage firm or insurance agency is responsible for our financial obligations arising under the policies.

Financial Condition of the Company

We pay benefits under Your Policy from our general account assets and/or from Your Policy Value held in the Separate Account. It is important that You understand that benefit payments are not assured and depend upon certain factors discussed below.

Assets in the Separate Account. You assume all of the investment risk for Your Policy Value that is allocated to the Subaccounts of the Separate Account. Your Policy Value in those Subaccounts constitutes a portion of the assets of the Separate Account. These assets are segregated and insulated from our general account, and may not be charged with liabilities arising from any other business that we may conduct. For more information see The Separate Account below.

Assets in the General Account. You also may be permitted to make allocations to Guaranteed Period Options of the Fixed Account, which are supported by the assets in our general account. Any guarantees under a Policy that exceed Policy Value, such as those associated with any lifetime withdrawal benefit riders and any optional death benefits, are paid from our general account (and not the Separate Account). Therefore, any amounts that we may be obligated to pay under the policy in excess of Policy Value are subject to our financial strength and claims-paying ability and our long-term ability to make such payments. The assets of the Separate Account, however, are also available to cover the liabilities of our general account, but only to the extent that the Separate Account assets exceed the Separate Account liabilities arising under the policies supported by it. For more information see The Fixed Account.

We issue other types of insurance policies and financial products as well, and we also pay our obligations under these products from our assets in the general account.

As an insurance company, we are required by state insurance regulation to hold a specified amount of general account reserves in order to meet all the contractual obligations to our Owners. We monitor our reserves so that we hold sufficient amounts to cover actual or expected Policy and claims payments. In addition, we monitor our reserves so that we hold sufficient amounts to cover actual or expected Policy and claims payments. In addition we hedge our investments in our general account, and may require purchasers of certain benefits of the variable insurance products that we offer to allocation premium payments and Policy Value in accordance with specified investment requirements. However, it is important to note that there is no guarantee that we will always be able to meet our claims-paying obligations, and that there are risks to purchasing any insurance product.

State insurance regulators also require insurance companies to maintain a minimum amount of capital, which acts as a cushion in the event that the insurer suffers a financial impairment, based on the inherent risks in the insurer’s operations. These risks include those associated with losses that we may incur as the result of defaults on the payment of interest or principal on our general account assets, which include bonds, mortgages, general real estate investments, and stocks, as well as the loss in market value of these investments. We may also experience liquidity risk if our general account assets cannot be readily converted into cash to meet obligations to our policy Owners or to provide the collateral necessary to finance our business operations.

How to Obtain More Information. We encourage Owners to read and understand our financial statements. We prepare our financial statements on a statutory basis. Our financial statements, which are presented in conformity with accounting practices prescribed or permitted by the Iowa Department of Insurance as well as the financial statements of the Separate Account are located in the Statement of Additional Information (SAI). For a free copy of the SAI, simply call or write us at the phone number or address of our Administrative Office referenced in this prospectus. In addition, the SAI is available on the SEC’s website at SEC.gov. Our financial strength ratings which reflect the opinions of leading independent rating agencies of our ability to meet our obligations to our Owners, are available on our website https://www.transamerica.com/why-transamerica/financial-strength, and the websites of these nationally recognized statistical ratings organizations – https://www.ambest.com/home/default.aspx, https://www.moodys.com/, and https://www.spglobal.com/ratings/en/.

The Separate Account

Each Separate Account receives and invests the premium payments that are allocated to it for investment in shares of the underlying fund portfolios. Each Separate Account is registered with the SEC as a unit investment trust under the 1940 Act. However, the SEC does not supervise the management, the investment practices, or the policies of the Separate Account or us. Income, gains and losses (whether or not realized), from assets allocated to the Separate Account are, in accordance with the policies, credited to or charged against the Separate Account without regard to our other income, gains or losses.

The assets of each Separate Account are held in our name on behalf of the Separate Account and belong to us. However, those assets that underlie the policies are not chargeable with liabilities arising out of any other business we may conduct. The Separate Account may include other Subaccounts that are not available under these policies. We do not guarantee the investment results of the Separate Account.

The Underlying Fund Portfolios

At the time You purchase Your Policy, You may allocate Your premium payment to Subaccounts. These are subdivisions of our Separate Account, an account that keeps Your Policy assets separate from our company assets. The Subaccounts then purchase shares of underlying fund portfolios set up exclusively for variable annuity or variable life insurance products. These are not the same mutual funds that You buy through Your investment professional even though they may have similar investment strategies and the same portfolio managers. Each underlying fund portfolio has varying degrees of investment risk. Underlying fund portfolios are also subject to separate fees and expenses such as management fees and operating expenses. “Master-feeder” or “fund of funds” invest substantially all of their assets in other mutual funds and will therefore bear a pro-rata share of fees and expenses incurred by both funds. This will reduce Your investment return. Read the underlying fund portfolio prospectuses carefully before investing. We do not guarantee the investment results of any underlying fund portfolio. Certain underlying fund portfolios may not be available in all states and in all share classes. Please see Appendix - Portfolio Companies Available Under the Policy for additional information.

Other Transamerica Policies

We offer a variety of fixed and variable annuity policies. They may offer features, including Investment Options, and have fees and charges, that are different from those in the Policy offered by this prospectus. Not every Policy we issue is offered through every financial intermediary. Some financial intermediaries may not offer and/or limit the offering of certain features or options, as well as limit the availability of the policies, based on issue Age, or other criteria established by the financial intermediary. Upon request, Your financial professional can show You information regarding other Transamerica annuity policies that he or she distributes. You can also contact us to find out more about the availability of any of the Transamerica annuity policies.

You should work with Your financial professional to decide whether this Policy is appropriate for You based on a thorough analysis of Your particular insurance needs, financial objectives, investment goals, time horizons and risk tolerance.

VOTING RIGHTS

To the extent required by law, we will vote the underlying fund portfolios' shares held by the Separate Account at regular and special shareholder meetings of the underlying fund portfolios in accordance with instructions received from persons having voting interests in the portfolios, although none of the underlying fund portfolios hold regular annual shareholder meetings. If, however, the 1940 Act or any regulation thereunder should be amended or if the present interpretation thereof should change, and as a result we will determine that it is permitted to vote the underlying fund portfolios shares in its own right, it may elect to do so.

Before the Annuity Commencement Date, You hold the voting interest in the selected portfolios. The number of votes that You have the right to instruct will be calculated separately for each Subaccount. The number of votes that You have the right to instruct for a particular Subaccount will be determined by dividing Your Policy Value in the Subaccount by the net asset value per share of the corresponding portfolio in which the Subaccount invests. Fractional shares will be counted.

After the Annuity Commencement Date, You have the voting interest, and the number of votes decreases as annuity payments are made and as the reserves for the Policy decrease. The person's number of votes will be determined by dividing the reserve for the Policy allocated to the applicable Subaccount by the net asset value per share of the corresponding portfolio. Fractional shares will be counted.

The number of votes that You have the right to instruct will be determined as of the date established by the underlying fund portfolio for determining shareholders eligible to vote at the meeting of the underlying fund portfolio. We will solicit voting instructions by sending You, or other persons entitled to vote, requests for instructions prior to that meeting in accordance with procedures established by the underlying fund portfolio. Portfolio shares as to which no timely instructions are received, and shares held by us in which You, or other persons entitled to vote have no beneficial interest, will be voted in proportion to the voting instructions that are received with respect to all policies participating in the same Subaccount. Accordingly, it is possible for a small number of Owners (assuming there is a quorum) to determine the outcome of a vote, especially if they have large Policy Values. If, however, we determine that we are permitted to vote the shares in our own right, we may do so. Shares owned by the insurance company and its affiliates will also be proportionately voted.

Each person having a voting interest in a Subaccount will receive proxy material, reports, and other materials relating to the appropriate portfolio.

THE ANNUITY Policy

This prospectus describes information You should know before You purchase the Transamerica Variable Annuity O-Share.

An annuity is a contract between You (the Owner) and an insurance company (in this case us), where the insurance company promises to pay You an income in the form of annuity payments. These payments begin on a designated date, referred to as the Annuity Commencement Date. Until the Annuity Commencement Date, Your annuity is in the accumulation phase and the earnings (if any) are generally tax deferred. Tax deferral means You are not taxed until You take money out of Your annuity. After You Annuitize, Your annuity switches to the income phase.

The Policy is a “deferred” annuity. You can use the Policy to accumulate assets for retirement or other long-term financial planning purposes. Your individual investment and Your rights are determined primarily by Your own Policy.

The Policy is a “flexible premium” annuity because after You purchase it, You can generally make additional premium payments of at least $50 (but not more than the stated maximum total premium payment amount) until the Annuity Commencement Date. You are not required to make any additional premium payments.

The Policy is a “variable” annuity because the value of Your Policy can go up or down based on the performance of Your Subaccounts. If You invest in the Separate Account, the amount of money You are able to accumulate in Your Policy during the accumulation phase depends upon the performance of Your Subaccounts. You could lose the amount You allocate to the Separate Account. The amount of annuity payments You receive during the income phase from the Separate Account also depends upon the investment performance of Your Subaccounts for the income phase.

The Fixed Account offers interest at a rate(s) that we guarantee will not decrease during the selected guaranteed period we may offer. There may be different interest rates for each different guaranteed period that we may offer and that You select.

Do not purchase this Policy if You plan to use it, or any of its riders, for resale, speculation, arbitrage, viatication, or any other type of collective investment scheme. Your Policy is not intended or designed to be traded on any stock exchange or secondary market. By purchasing this Policy, You represent and warrant that You are not using the Policy, or any of its riders for resale, speculation, arbitrage, viatication, or any other type of collective investment scheme.

PURCHASE

Policy Issue Requirements

We will not issue a Policy unless:

●

we receive in good order (See Sending Forms and Transaction Requests in Good Order) all information needed to issue the Policy;

●

we receive in good order (at our Administrative Office) a minimum initial premium payment; and

●

the Annuitant, Owner, and any joint Owner are age 85 or younger (the limit may be lower for qualified policies and certain optional benefits).

●

the Owner and Annuitant have an immediate familial relationship.

For policies sold through certain financial intermediaries, we will not issue a Policy unless:

●

we receive in good order (See Sending Forms and Transaction Requests in Good Order) all information needed to issue the Policy;

●

we receive in good order (at our Administrative Office) a minimum initial premium payment (including anticipated premiums from transfers or rollovers for qualified policies and from 1035 exchanges for non-qualified policies as indicated on Your application or electronic order form);

●

the Owner is the Annuitant (except with respect to non-natural Owners);

●

there are no joint Owners; and

●

the Annuitant, Owner, and any joint Owner are age 85 or younger (the limit may be lower for qualified policies and certain optional benefits).

Please note, certain riders described herein may require a younger age. Please carefully read the applicable rider sections regarding any age limitations.

We reserve the right to reject any application.

In some cases, an ownership structure not available through a financial intermediary may be obtained by contacting us directly. For more information on the ownership options available, please contact Your financial intermediary or our Administrative Office.

Premium Payments

General. You should make checks for premium payments payable to Transamerica Life Insurance Company or Transamerica Financial Life Insurance Company, as applicable, and send them to the Administrative Office. Your check must be honored in order for us to pay any associated annuity payments and benefits due under the Policy.

We do not accept cash. We reserve the right to not accept third party checks. A third party check is a check that is made payable to one person who endorses it and offers it as payment to a second person. Checks should normally be payable to us, however, in some circumstances, at our discretion we may accept third party checks that are from a rollover or transfer from other financial institutions. Any third party checks not accepted by us will be returned.

We reserve the right to reject or accept any form of payment. Any unacceptable forms of payment will be returned.

Initial Premium Requirements. The initial premium payment must be at least $10,000 (including anticipated premiums from transfers or rollovers for qualified policies and Internal Revenue Code Section 1035 exchanges for nonqualified policies as indicated on Your application or electronic order form) You must obtain our prior approval to purchase a Policy with an amount in excess of our maximum premium amount.

Your initial premium payment may not be credited to Your Policy on the day that You leave Your premium payment with Your financial intermediary. Your financial intermediary may take up to seven Business Days to assess whether buying this Policy is suitable for You. Your financial intermediary may send us Your initial premium payment while they complete this assessment. Your financial intermediary must also ensure that we have all the information needed for us to process Your Policy. We will not begin to process Your Policy during this period.

We will first begin our review only once we receive both Your initial premium payment and Your application (or an electronic order form). We will credit Your initial premium payment to Your Policy within two Business Days after the Business Day that we receive Your initial premium payment, Your application (or order form) and once we determine that Your Policy information is both complete and in good order. This time period is in addition to the time Your financial intermediary may take to complete their part of the process. If we are unable to complete our part of the process within five Business Days from the Business Day that we receive Your initial premium payment and Your application (or electronic order form) that we need, then we will notify You or Your financial intermediary and explain why we can't process Your Policy. We will also return Your initial premium payment at that time unless You consent to us holding the premium up to 30 days. We must receive Your consent to hold prior to the market close on the fifth Business Day after receipt of the premium. If Your information is not received in good order within 30 days of our receipt of the premium, then it will be returned. We will credit Your initial premium payment within two Business Days after Your information is both complete and in good order.

Neither we nor Your financial intermediary are responsible for lost investment opportunities while we each complete our review processes. Any initial premium payments received by us will be held in our general account until credited to Your Policy. You will not earn interest on Your initial premium payment during these review periods.

The date on which we credit Your initial premium payment to Your Policy is generally the Policy Date. The Policy Date is used to determine Policy Years, Policy quarters, Policy months and Policy anniversaries.

Additional Premium Payments. You are not required to make any additional premium payments. However, You can generally make additional premium payments during the accumulation phase. Additional premium payments must be at least $50. After the first Policy Year, additional premium payments each Policy Year cannot, in the aggregate, exceed $25,000 for nonqualified policies and the lesser of (1) the IRS maximum contribution limit or (2) $60,000 for qualified policies. We reserve the right to refuse any additional premium payment in excess of these limits, and if You do not obtain prior approval for premiums in excess of the dollar amounts listed above, the business will be deemed not in good order. We will credit additional premium payments to Your Policy as of the Business Day we receive Your premium and required information in good order at our Administrative Office. Additional premium payments must be received in good order before the close of regular trading on the New York Stock Exchange (usually 4:00 p.m. Eastern Time) to get same-day pricing of the additional premium payment.

Maximum Total Premium Payments. For issue ages 0-80, we reserve the right to require prior approval of any cumulative premium payments over $1,000,000 (this includes subsequent premium payments) for policies with the same Owner or same Annuitant issued by us or an affiliate. For issue ages over 80, we reserve the right to require prior approval of any cumulative premium payments over $500,000 (this includes subsequent premium payments) for policies with the same Owner or same Annuitant issued by us or an affiliate. If You do not obtain prior approval for premium payments in excess of the dollar amounts listed above, the business will be deemed not in good order.

Allocation of Premium Payments. When You purchase a Policy, we will allocate Your premium payment to the Investment Options You select. Your allocation must be in whole percentages and must total 100%. We will allocate additional premium payments the same way, unless You request a different allocation. You could lose the amount You allocate to the variable Subaccounts.

If You allocate premium payments to the Dollar Cost Averaging program (if it is available), You must give us instructions regarding the Subaccount(s) to which transfers are to be made or we cannot accept Your premium payment.

You may change allocations for future additional premium payments by sending written instructions to our Administrative Office, or by telephone, or other electronic means acceptable to us, subject to the limitations described in ADDITIONAL FEATURES - Telephone and Electronic Transactions, or any other means acceptable to us. The allocation change will apply to premium payments received on or after the date we receive the change request in good order.

Policy Value

You should expect Your Policy Value to change from Valuation Period to Valuation Period. A Valuation Period begins at the close of regular trading on the New York Stock Exchange on each Business Day and ends at the close of regular trading on the next succeeding Business Day. A Business Day is each day that the New York Stock Exchange is open for business. Regular trading on the New York Stock Exchange usually closes at 4:00 p.m., Eastern Time. Holidays are generally not Business Days.

INVESTMENT OPTIONS

This Policy offers You a means of investing in various underlying fund portfolios offered by different investment companies (by investing in the corresponding Subaccounts). The companies that provide investment advice and administrative services for the underlying fund portfolios offered through this Policy are listed in the Appendix - Portfolio Companies Available Under the Policy.

The general public may not purchase shares of any of these underlying fund portfolios. The names and investment objectives and policies may be similar to other portfolios managed by the same investment adviser or manager that are sold directly to the public. You should not expect the investment results of the underlying fund portfolios to be the same as those of other portfolios.

More detailed information, including an explanation of the portfolios' fees and investment objectives, may be found in the current prospectuses for the underlying fund portfolios, which can be found at http://dfinview.com/Transamerica/TAHD/89354G745?site=VAVUL. You should read the prospectuses for the underlying fund portfolios carefully before You invest.

In addition, information regarding each underlying fund portfolio, including (i) its name (ii) its investment objective (iii) its investment adviser and any sub-investment adviser (iv) current expenses and (v) performance is available in the Appendix - Portfolio Companies Available Under the Policy. Each underlying fund portfolio has issued a prospectus that contains more detailed information about its investment holdings, including a description of investment risks. You may obtain a free copy of the underlying fund portfolio prospectuses by contacting our Administrative Office at (800)525-6205 or by visiting our website at http://dfinview.com/Transamerica/TAHD/89354G745?site=VAVUL.

Note: If You received a summary prospectus for any of the underlying fund portfolios listed in Appendix - Portfolio Companies Available Under the Policy, please follow the instructions on the first page of the summary prospectus to obtain a copy of the full underlying fund prospectus or its Statement of Additional Information.

Selection of Underlying Fund Portfolios

The underlying fund portfolios offered through this variable annuity are selected by us, and we may consider various factors, including, but not limited to, asset class coverage, the strength of the adviser's or sub-adviser's reputation and tenure, brand recognition, performance, volatility, hedge ability, and the capability and qualification of each investment firm. Another factor that we may consider is whether the underlying fund portfolio or its service providers (e.g., the investment adviser or sub-advisers) or its affiliates will make payments to us or our affiliates. For additional information about these arrangements, see Revenue We Receive. We review the portfolios periodically and may remove a portfolio, or limit its availability to new premium payments and/or transfers of Cash Value if we determine that a portfolio no longer satisfies one or more of the selection criteria, and/or if the portfolio has not attracted significant allocations from Owners. We have included the Transamerica Series Trust (“TST” ) underlying fund portfolios at least in part because they are managed by one of our affiliates, Transamerica Asset Management, Inc. (“TAM”).

We have developed this variable annuity in cooperation with one or more distributors, and may include certain underlying fund portfolios based on their recommendations. Their selection criteria may differ from our selection criteria.

If You elect a Guaranteed Lifetime Withdrawal Benefit rider, as discussed later in this prospectus, we require You to allocate Your Policy Value to designated Investment Options. This requirement is intended to reduce the Company’s costs and risks associated with offering the rider, and we select which underlying fund portfolios to make available under the riders with these factors in mind. Certain designated Investment Options invest in underlying fund portfolios with volatility control strategies, which could limit full participation in market gains and the growth of the riders. See the Investment Restrictions section for information regarding the potential impact of volatility control strategies on the value of the Guaranteed Lifetime Withdrawal Benefit riders.

Designated Investment Options, including those that invest in underlying fund portfolios with volatility control strategies, are also available to Owners who do not elect a Guaranteed Lifetime Withdrawal Benefit rider. Although volatility control strategies are intended to help limit overall volatility and reduce the effects of significant market downturns during periods of high market volatility, providing Policy Owners with the opportunity for smoother performance and better risk adjusted returns, such strategies could limit Your full participation in market gains and ability to maximize potential growth of Your Policy Value.

You are responsible for choosing the Subaccounts which invest in the underlying fund portfolios, and the amounts allocated to each, that are appropriate for Your own individual circumstances and Your investment goals, financial situation, and risk tolerance. Because investment risk is borne by You, decisions regarding investment allocations should be carefully considered. We do not recommend or endorse any particular underlying fund portfolio and we do not provide investment advice.

In making Your investment selections, we encourage You to thoroughly investigate all of the information regarding the underlying fund portfolios that are available to You, including each underlying fund portfolio's prospectus, statement of additional information and annual and semi-annual reports. Other sources such as the underlying fund's website provide more current information, including information about any regulatory actions or investigations relating to a fund or underlying fund portfolio. After You select underlying fund portfolios for Your initial premium payment, You should monitor and periodically re-evaluate Your allocations to determine if they are still appropriate.

You bear the risk of any decline in the Cash Value of Your Policy resulting from the performance of the underlying fund portfolios You have chosen.

We do not guarantee that any of the Subaccounts will always be available for premium payments, allocations, or transfers.

We reserve the right to limit the number of Subaccounts You are invested in at any one time.

If You elect certain optional riders, You will be subject to Investment Restrictions. In the future, we may change the Investment Restrictions.

Not all Subaccounts may be available for all policies, in all states, or through all financial intermediary firms.

Addition, Deletion, or Substitution of Investment Options

We cannot and do not guarantee that any of the Subaccounts will always be available for premium payments, allocations, or transfers. We retain the right, subject to any applicable law, to make certain changes to the Separate Account and its Investment Options. We reserve the right to add new Subaccounts or close existing Subaccounts. We also reserve the right to eliminate the shares of any portfolio held by a Subaccount and to substitute shares of other underlying fund portfolios or of other registered open-end management investment companies. To the extent required by applicable law, substitutions of shares attributable to Your interest in a Subaccount will not be made without prior notice to You and the prior regulatory approval. Nothing contained herein shall prevent the Separate Account from purchasing other securities for other series or classes of variable annuity policies, or from affecting an exchange between series or classes of variable annuity policies on the basis of Your requests.

New Subaccounts may be established when, in our sole discretion, marketing, tax, investment or other conditions warrant. Any new Subaccounts may be made available to existing Owners on a basis to be determined by us. Each additional Subaccount will purchase shares in an underlying fund portfolio or other investment vehicle. We may also close one or more Subaccounts if, in our sole discretion, marketing, tax, investment or other conditions warrant such change. In the event any Subaccount is closed, we will notify You and request a reallocation of the amounts invested in the closed Subaccount. If we do not receive additional instructions, any subsequent premium payments, or transfers (including Dollar Cost Averaging transactions or asset rebalance programs transactions) into a closed Subaccount will be re-allocated to the remaining available Investment Options according to the investment allocation instructions You previously provided. If Your previous investment allocation instructions do not include any available Investment Options, we will require new instructions. If we do not receive new instructions, the requested transaction will be canceled and any premium payment will be returned. Under asset rebalance programs the value remaining in the closed Subaccount will be excluded from any future rebalancing. The value of the closed Subaccount will continue to fluctuate due to portfolio performance, and may exceed the original rebalance percentages You requested. As You consider Your overall investment strategy within Your Policy, You should also consider whether or not to re-allocate the value remaining in the closed Subaccount to another Investment Option. If You decide to re-allocate the value of the closed Subaccount, You will need to provide us with instructions. Under certain situations involving death benefit adjustments for continued policies, if an Investment Option is closed to new investment, the amount that would have been allocated thereto will instead be allocated pro rata to the other current Investment Options You have value allocated to and which are open to new investment.

In the event of any such substitution or change, we may, by appropriate endorsement, make such changes in the policies as may be necessary or appropriate to reflect such substitution or change. Furthermore, if deemed to be in the best interests of persons having voting rights under the policies, the Separate Account may be (1) operated as a management company under the 1940 Act or any other form permitted by law, (2) deregistered under the 1940 Act in the event such registration is no longer required or (3) combined with one or more other Separate Accounts. To the extent permitted by applicable law, we also may (1) transfer the assets of the Separate Account associated with the policies to another account or accounts, (2) restrict or eliminate any voting rights of Owners or other persons who have voting rights as to the Separate Account, (3) create new Separate Accounts, (4) add new Subaccounts to or remove existing Subaccounts from the Separate Account, or combine Subaccounts or (5) add new underlying fund portfolios, or substitute a new underlying fund portfolio for an existing underlying fund portfolio.

In addition, a Subaccount could become no longer available due to the liquidation of its corresponding underlying fund portfolio. To the extent permitted by applicable law, upon advance notice to You and unless You otherwise instruct us, we will:

Re-allocate any Policy Value in the liquidated underlying fund portfolio to the money market Subaccount or a Subaccount investing in another underlying fund portfolio designated by us; and

If You are using an automated transfer feature such as the Rebalancing program or Dollar Cost averaging with the Subaccount for the portfolio, You should contact us immediately to make alternate arrangements. If you do not make alternate arrangements before the closure date, any subsequent allocations to the Subaccount for the portfolio will be directed to the Money Market Subaccount.

We reserve the right, subject to compliance with applicable law, to make certain changes to the Separate Account and its investments. We reserve the right to add new portfolios (or portfolio classes), close existing portfolios (or portfolio classes), or substitute portfolio shares that are held by any Subaccount for shares of a different portfolio. We will not add, delete or substitute any Underlying Fund Portfolio shares attributable to Your interest in a Subaccount without notice to You and prior approval of the SEC, to the extent required by the 1940 Act or other applicable law.

The Fixed Account

The Fixed Account may, but is not guaranteed to always, be available. If available, premium payments allocated and amounts transferred to the Fixed Account become part of our general account. Interests in the general account have not been registered under the Securities Act of 1933 (the “1933 Act”), nor is the general account registered as an investment company under the 1940 Act. Accordingly, neither the general account nor any interests therein are generally subject to the provisions of the 1933 or 1940 Acts. Disclosures relating to interests in the general account are, however, subject to certain generally applicable provisions of the federal securities laws relating to the accuracy of statements made in a registration statement.

The Fixed Account is currently available for investment as of the date of this prospectus. We will post a notice on our website if it is not available. You can also contact Your financial representative to see if it is available. While we do not guarantee that the Fixed Account will always be available for investment, we do guarantee that the interest credited to the Fixed Account when available will not be less than the guaranteed minimum effective annual interest rate shown on Your Policy (the “guaranteed minimum”) and in no event will be less than 0.25%. We determine credited rates, which are guaranteed for at least one year, in our sole discretion. You bear the risk that we will not credit interest greater than the guaranteed minimum. At the end of the Guaranteed Period Option You selected, the value in that Guaranteed Period Option will automatically be transferred into the money market Subaccount or if a money market Subaccount is unavailable to a new Guaranteed Period Option of the same length (or the next shorter period if the same period is no longer offered) at the current interest rate for that period. You can transfer to another Investment Option by giving us notice within 30 days before the end of the expiring guaranteed period.

Surrenders, withdrawals, transfers, and amounts applied to an Annuity Payment Option from a Guaranteed Period Option of the Fixed Account prior to the end of the guaranteed period are generally subject to an Excess Interest Adjustment. See ACCESS TO YOUR MONEY - Excess Interest Adjustment for more information about when an Excess Interest Adjustment applies. This adjustment will also be made to amounts that You apply to an Annuity Payment Option. The Excess Interest Adjustment will not decrease the interest credited to Your Policy below the guaranteed minimum. Please see Appendix – Excess Interest Adjustment Examples for an example showing the effect of a hypothetical Excess Interest Adjustment calculation.

We also guarantee that upon full surrender Your Cash Value attributable to the Fixed Account will not be less than the amount required by the applicable nonforfeiture law at the time the Policy is issued.

If You select the Fixed Account, when it is available, Your money will be placed with our other general assets. Assets in the Stable Account are not subject to Separate Account Annual Expenses as set forth under ANNUITY POLICY FEE TABLE AND EXPENSE EXAMPLES. The amount of money You are able to accumulate in the Fixed Account during the accumulation phase depends upon the total interest credited. The amount of each annuity payment You receive during the income phase from the fixed portion of Your Policy will remain level for the entire income phase. The interest credited as well as principal invested in the Fixed Account is based on our claims-paying ability.

We reserve the right to refuse any premium payment or transfer to the Fixed Account.

Transfers

During the accumulation phase, You may make transfers to or from any Investment Option within certain limitations. Transfers out of a Guaranteed Period Option of the Fixed Account are limited to the following:

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Transfers at the end of a guaranteed period.

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Transfers of amounts equal to interest credited. This may affect Your overall interest-crediting rate, because unless otherwise directed, transfers are deemed to come from the oldest premium payment first.

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Other than at the end of a guaranteed period, transfers of amounts from the Guaranteed Period Option in excess of amounts equal to interest credited, including transfers in connection with the Portfolio Allocation Method discussed later in this prospectus, are subject to an Excess Interest Adjustment. If it is a negative adjustment, the maximum amount you can transfer in any one Policy Year may be limited to 25% of the amount in that Guaranteed Period Option, less any previous transfers during the current Policy Year. If it is a positive adjustment, we do not limit the amount that you can transfer. (Note: This restriction may prolong the period of time it takes to transfer the full amount in the Guaranteed Period Option of the Fixed

Account. You should carefully consider whether investment in the Fixed Account meets your needs and investment criteria.) Please see Appendix - Excess Interest Adjustment Examples for an example showing the effect of a hypothetical Excess Interest Adjustment calculation.

In general, each transfer from a Subaccount must be at least $500, or the entire Subaccount value if less than $500. Transfers of interest from a Guaranteed Period Option of the Fixed Account must be at least $50. If less than $500 remains as a result of the transfer, then we reserve the right to include that amount in the transfer. Transfer requests must be received in good order while the New York Stock Exchange is open for regular trading to get same-day pricing of the transaction. Transfer requests received in good order on non-Business Days or after our close of business on Business Days will get next-day pricing. See Sending Forms and Transaction Requests in Good Order.

The number of transfers permitted may be limited and a $10 charge for each transfer in excess of 12 in any Policy Year may apply. Currently, we do not charge a transfer fee but reserve the right to do so in the future. We reserve the right to prohibit transfers to the Fixed Account.

During the income phase, You may transfer values out of any Subaccount; however, You cannot transfer values out of the Fixed Account. The minimum amount that can be transferred during this phase is the lesser of $10 of monthly income, or the entire monthly income of the annuity units in the Subaccount from which the transfer is being made.

Transfers made by telephone, or other electronic means acceptable to us, are subject to the limitations described in ADDITIONAL FEATURES - Telephone and Electronic Transactions.

Additional Restrictions for the Transamerica Income EdgeSM Rider. If You elect the Transamerica Income EdgeSM rider, a certain percentage of Your Policy Value must be allocated to the Stable Account, the select Investment Options and the flexible Investment Options as specified below. See Optional Benefit Riders - Transamerica Income EdgeSM Rider. Any transfer requests to and from the select Investment Options and flexible Investment Options will be validated using the prior Business Day’s Policy Value to ensure compliance with the required allocations for rebalancing at the time of the request. Transfer requests that do not comply with the required allocations for rebalancing will be deemed not in good order. Changes in Policy Values due to market movements on other dates will not be treated as a violation of the required allocations. Transfers to the Stable Account are not permitted except at the time of election of the rider. Transfers from the Stable Account are not permitted except upon termination of the rider.

Investment Restrictions

If You elect certain optional riders, You will be subject to Investment Restrictions requiring You to invest in certain underlying fund portfolios, which may be referred to (depending on Your rider) as designated Investment Options, flexible Investment Options and/or select Investment Options. In addition, the Transamerica Income Edge rider may require You to invest in the Stable Account.

One or more of the underlying fund portfolios that may be designated, flexible or select Investment Options under an optional rider, in part, may include a volatility control strategy. Volatility control strategies, in periods of high market volatility, could limit Your participation in market gains; this may conflict with Your investment objectives by limiting Your ability to maximize potential growth of Your Policy Value and, in turn, the value of any guaranteed benefit that is tied to investment performance. Volatility control strategies are intended to help limit overall volatility and reduce the effects of significant market downturns during periods of high market volatility, providing Policy Owners with the opportunity for smoother performance and better risk adjusted returns. Volatility control (and similar terms) can encompass a variety of investment strategies of different types and degrees; therefore, You should read the applicable annuity and underlying fund portfolio prospectuses carefully to understand how these investment strategies may affect Your Policy Value and rider benefits. Our requirement to invest in accordance with certain Investment Options, which may include volatility control, may reduce our costs and risks associated with the applicable riders. You pay an additional fee for the rider benefits which, in part, pays for protecting the rider benefit base from investment losses. Since the rider benefit base does not decrease as a result of investment losses, volatility control strategies might not provide meaningful additional benefit to You. You should carefully evaluate with Your financial professional whether to invest in underlying fund portfolios with volatility control strategies, taking into consideration the potential positive or negative impact that such strategy may have on Your investment objectives, Your Policy Value and the benefits under the riders. If You determine that underlying fund portfolios with volatility control strategies are not consistent with Your investment objectives, other Investment Options are available under the riders that do not invest in underlying fund portfolios that utilize volatility control strategies.

For more information about the underlying fund portfolios and the investment strategies they employ, please refer to the underlying fund portfolios' current prospectuses.

Market Timing and Disruptive Trading

Statement of Policy. This variable annuity Policy was not designed to accommodate market timing or facilitate frequent or large transfers among the Subaccounts or between the Subaccounts and the Fixed Account. (Both frequent and large transfers may be considered disruptive.)

Market timing and disruptive trading can adversely affect You, other Owners, beneficiaries and underlying fund portfolios. The adverse effects may include: (1) dilution of the interests of long-term investors in a Subaccount if purchases or transfers into or out of an underlying fund portfolio are made at prices that do not reflect an accurate value for the underlying fund portfolio’s investments (some market timers attempt to do this through methods known as “time-zone arbitrage” and “liquidity arbitrage”); (2) an adverse effect on portfolio management, such as (a) impeding a portfolio manager’s ability to seek or sustain an investment objective; (b) causing the underlying fund portfolio to maintain a higher level of cash than would otherwise be the case; or (c) causing an underlying fund portfolio to liquidate investments prematurely (or otherwise at an inopportune time) in order to pay withdrawals or transfers out of the underlying fund portfolio; and (3) increased brokerage and administrative expenses. These risks and costs are borne by all Owners invested in those Subaccounts, not just those making the transfers.

We have developed policies and procedures with respect to market timing and disruptive trading (which vary for certain Subaccounts at the request of the corresponding underlying fund portfolios) and we do not make special arrangements or grant exceptions to accommodate market timing or potentially disruptive trading. As discussed herein, we cannot detect or deter all market timing or potentially disruptive trading. Do not invest with us if You intend to conduct market timing or potentially disruptive trading or have concerns about our inability to detect or prevent any such trading.

Detection. We employ various means in an attempt to detect and deter market timing and disruptive trading. However, despite our monitoring we may not be able to detect nor halt all harmful trading. In addition, because other insurance companies (and retirement plans) with different policies and procedures may invest in the underlying fund portfolios, we cannot guarantee that all harmful trading will be detected or that an underlying fund portfolio will not suffer harm from market timing and disruptive trading among Subaccounts of variable products issued by these other insurance companies or retirement plans.

Deterrence. If we determine You or anyone acting on Your behalf is engaged in market timing or disruptive trading, we may take one or more actions in an attempt to halt such trading. Your ability to make transfers is subject to modification or restriction if we determine, in our sole opinion, that Your exercise of the transfer privilege may disadvantage or potentially harm the rights or interests of other Owners (or others having an interest in the variable insurance products). As described below, restrictions may take various forms, but under our current policies and procedures will include loss of expedited transfer privileges. We consider transfers by telephone, fax, overnight mail, or the Internet to be “expedited” transfers. This means that we would accept only written transfer requests with an original signature sent to us only by U.S. mail. We may also restrict the transfer privileges of others acting on Your behalf, including Your registered representative or an asset allocation or investment advisory service.

We reserve the right to reject any premium payment or transfer request from any person without prior notice, if, in our judgment, (1) the premium payment or transfer, or series of premium payments or transfers, would have a negative impact on an underlying fund portfolio's operations, or (2) if an underlying fund portfolio would reject or has rejected our purchase order or has instructed us not to allow that purchase or transfer, or (3) because of a history of market timing or disruptive trading. We may impose other restrictions on transfers, or even prohibit transfers for any Owner who, in our view, has abused, or appears likely to abuse, the transfer privilege on a case-by-case basis. We may, at any time and without prior notice, discontinue transfer privileges, modify our procedures, impose holding period requirements or limit the number, size, frequency, manner, or timing of transfers we permit. We also reserve the right to reverse a potentially harmful transfer if an underlying fund portfolio refuses or reverses our order; in such instances some Owners may be treated differently than others in that some transfers may be reversed and others allowed. For all of these purposes, we may aggregate two or more trades or variable insurance products that we believe are connected by Owner or persons engaged in trading on behalf of Owners.

In addition, transfers for multiple policies invested in the Transamerica Series Trust underlying fund portfolios which are submitted together may be disruptive at certain levels. At the present time, such aggregated transactions likely will not cause disruption if less than one million dollars total is being transferred with respect to any one underlying fund portfolio (a smaller amount may apply to smaller underlying fund portfolios). Please note that transfers of less than one million dollars may be disruptive in some circumstances; we may change the maximum dollar mount of permitted transfer quickly and without notice.

Please note: If You engage a third party investment adviser for asset allocation services, then You may be subject to these transfer restrictions because of the actions of Your investment adviser in providing these services.

In addition to our internal policies and procedures, we will administer Your variable annuity Policy to comply with any applicable state, federal, and other regulatory requirements concerning transfers. We reserve the right to implement, administer, and charge You for any fee or restriction, including redemption fees, imposed by any underlying fund portfolio. To the extent permitted by law, we also reserve the right to defer the transfer privilege at any time that we are unable to purchase or redeem shares of any of the underlying fund portfolios.

Under our current policies and procedures, we do not:

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impose redemption fees on transfers; or

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expressly limit the number or size of transfers in a given period except for certain Subaccounts where an underlying fund portfolio has advised us to prohibit certain transfers that exceed a certain size; or

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provide a certain number of allowable transfers in a given period.

Redemption fees, transfer limits, and other procedures or restrictions imposed by the underlying fund portfolios or our competitors may be more or less successful than ours in deterring market timing or other disruptive trading and in preventing or limiting harm from such trading.

In the absence of preventative transfer restriction (e.g., expressly limiting the number of trades within a given period or limiting trades by their size), it is possible that some level of market timing and disruptive trading will occur before it is detected and steps taken to deter it.

Please note that the limits and restrictions described herein are subject to our ability to monitor transfer activity. Our ability to detect market timing or disruptive trading may be limited by operational and technological systems, as well as by our ability to predict strategies employed by Owners (or those acting on their behalf) to avoid detection. As a result, despite our efforts to prevent harmful trading activity among the variable Investment Options available under this variable insurance product, there is no assurance that we will be able to detect or deter market timing or disruptive trading by such Owners or intermediaries acting on their behalf. Moreover, our ability to discourage and restrict market timing or disruptive trading may be limited by decisions of state regulatory bodies and court orders that we cannot predict.

Furthermore, we may revise our policies and procedures in our sole discretion at any time and without prior notice, as we deem necessary or appropriate (1) to better detect and deter harmful trading that may adversely affect other Owners, other persons with material rights under the variable insurance products, or underlying fund shareholders generally, (2) to comply with state or federal regulatory requirements, or (3) to impose additional or alternative restrictions on Owners engaging in market timing or disruptive trading among the Investment Options under the variable insurance product. In addition, we may not honor transfer requests if any variable Investment Option that would be affected by the transfer is unable to purchase or redeem shares of its corresponding underlying fund portfolio.

Underlying Fund Portfolio Frequent Trading Policies. The underlying fund portfolios may have adopted their own policies and procedures with respect to frequent purchases and redemptions of their respective shares. Underlying fund portfolios may, for example, assess a redemption fee (which we reserve the right to collect) on shares held for less than a certain period of time. The prospectuses for the underlying fund portfolios describe any such policies and procedures. The frequent trading policies and procedures of an underlying fund portfolio may be different, and more or less restrictive, than the frequent trading policies and procedures of other underlying fund portfolios and the policies and procedures we have adopted for our variable insurance products to discourage market timing and disruptive trading. We do not monitor transfer requests for compliance with the frequent trading policies and procedures of the respective underlying fund portfolios.

We are required to provide to an underlying fund portfolio or its payee certain information about the trading activity of individual Owners. We are required to restrict or prohibit further purchases or transfers by specific Owners or persons acting on their behalf, if identified by an underlying fund portfolio as violating frequent trading policies.

Please read the underlying fund portfolio prospectus for information about restrictions on transfers.

Omnibus Orders. Owners and other persons with material rights under the variable insurance products also should be aware that the purchase and redemption orders received by the underlying fund portfolios generally are “omnibus” orders from intermediaries such as retirement plans and Separate Accounts funding variable insurance products. The omnibus orders reflect the aggregation and netting of multiple orders from individual retirement plan participants and individual Owners of variable insurance products. The omnibus nature of these orders may limit the underlying fund portfolio companies' ability to apply their respective frequent trading policies and procedures.

We cannot guarantee that the underlying fund portfolios will not be harmed by transfer activity relating to the retirement plans or other insurance companies that may invest in the underlying fund portfolios. These other insurance companies are responsible for their own policies and procedures regarding frequent transfer activity. If their policies and procedures fail to successfully discourage harmful transfer activity, it may affect other Owners of underlying fund portfolio shares, as well as the Owners of all of the variable annuity or life insurance policies, including ours, whose variable Investment Options correspond to the affected underlying fund portfolios. In addition, if an underlying fund portfolio believes that an omnibus order we submit may reflect one or more transfer requests from Owners engaged in market timing and disruptive trading, the underlying fund portfolio may reject the entire omnibus order and thereby delay or prevent us from implementing Your request.

EXPENSES

There are charges and expenses associated with Your Policy that reduce the return on Your investment in the Policy. In addition to the following charges, there are optional benefits that if selected, assess additional charges. Please see ADDITIONAL FEATURES for more information.

Transaction Expenses:

Premium Based Charge

We charge a fee to compensate us for the expenses we incur for Policy distribution. Each premium payment is subject to its own Premium Based Charge that will be deducted in quarterly installments for seven years after that premium payment is received by us (referred to as the Premium Based Charge period). The charge for each premium payment is determined by multiplying the premium payment by the applicable percentage shown in the Annuity Policy Fee Table. The Premium Based Charge percentage for new premium payments decreases as the total amount of premium payments increase beyond certain thresholds. For example, if You make an initial premium payment of $40,000, the Premium Based Charge percentage will be based on a total premium payment amount of $40,000. For each new premium payment, the Premium Based Charge percentage is based on the sum of all premium payments previously received, including the newest premium payment. For example, assuming Your initial premium payment of $40,000, You make a subsequent premium payment of $20,000 six months later; the quarterly Premium Based Charge percentage for that subsequent premium payment will be based on the total premium of $60,000. Please note that the Premium Based Charge percentage for each premium payment, once set, will not be reduced by any new premium payment.

This fee is deducted from the Investment Options. We will also deduct this fee on certain surrenders for premium payments less than seven years old. See Appendix - Premium Based Charges. If a portion of the total remaining Premium Based Charge amount is deducted as a Surrender Charge, then we will reduce the dollar amount of the Premium Based Charge that is assessed quarterly going forward. See Appendix - Premium Based Charges for an example of how the Premium Based Charge is reduced.

If You make additional premium payments during the committed premium period (which begins on the Policy Date and continues through the first quarterversary), we will determine Your Premium Based Charge percentage based on the total amount You invest during the committed premium period. For example, if Your initial premium payment is $90,000, and You invest an additional $10,000 during the committed premium period (for total premium payments equal to $100,000), the Premium Based Charge will be calculated based on the total invested of $100,000 (total Premium Based Charge of 3.5%) instead of Your initial premium payment of $90,000 (Premium Based Charge of 4.5%) and a total charge of 3.5% for the subsequent $10,000 premium payment.

Surrender Charges

During the accumulation phase, You can withdraw or surrender part or all of the Cash Value (restrictions may apply to qualified policies). We may apply a Surrender Charge to compensate us for Policy distribution expenses, including commissions to registered representatives and other promotional expenses. The Surrender Charge is an acceleration of some or all of the remaining Premium Based Charge. There is no Surrender Charge for a particular premium payment after seven years.

Each year You can withdraw up to a certain amount from your Policy free of surrender charges. This amount is referred to as the Surrender Charge Free Amount and is determined at the time of surrender. The Surrender Charge Free Amount is equal to (1) 100% of the premium payments with no remaining Premium Based Charge plus (2) the 10% free amount, not to exceed the current Cash Value. The 10% free amount is equal to 10% of all premium payments with a remaining Premium Based Charge, less any previously withdrawn premium payments with a remaining Premium Based Charge in the same Policy Year. See the Statement of Additional Information for detailed information concerning the order of operations when calculating Surrender Charges. The 10% free amount is not cumulative, so not withdrawing anything in one year does not increase the 10% free amount in subsequent years. If the withdrawal is in excess of the Surrender Charge Free Amount, You might have to pay a Surrender Charge, which is a contingent deferred sales charge, on the excess amount.

If You surrender Your Policy, the Surrender Charge is equal to any remaining Premium Based Charge. This means there is no 10% free amount if You surrender Your Policy. Moreover, if You make a withdrawal that exceeds the Surrender Charge Free Amount, a portion of the remaining Premium Based Charge will be deducted from Your Policy Value at that time. Withdrawals less than or equal to the Surrender Charge Free Amount are not subject to this deduction.

For tax-qualified plans and policies, withdrawals taken to satisfy the current calendar year required minimum distribution requirements under Section 401(a)(9) of the Internal Revenue Code are available with no Surrender Charges. The amount available from this Policy with respect to the required minimum distribution is based solely on this Policy. All withdrawals taken during the current calendar year will reduce the remaining amount available that same calendar year without Surrender Charges. The Surrender Charge Free Amount and the required minimum distribution amount are not cumulative. Withdrawals taken to satisfy required minimum distribution requirements which exceed the Surrender Charge Free Amount will not reduce remaining premium payments or cause a reduction in any remaining Premium Based Charge. See the Statement of Additional Information for detailed information concerning the order of operations when calculating Surrender Charges.

Any amount requested in excess of the required minimum distribution described above will have the appropriate Surrender Charges applied.

You can generally choose to receive the full amount of a requested withdrawal by directing us to deduct any applicable Surrender Charge (and any applicable Excess Interest Adjustment) from Your remaining Policy Value. You receive Your Cash Value upon surrender.

Surrender charges and Excess Interest Adjustments are waived under the Nursing Care and Terminal Condition Withdrawal Option and the Unemployment Waiver. Amounts withdrawn under these options reduce Your Surrender Charge Free Amount.

For Surrender Charge purposes, the oldest premium payment is considered to be withdrawn first, then the next oldest premium payment, etc., with earnings being considered surrendered or withdrawn last. Please note, withdrawals of the Surrender Charge Free Amount are not considered as a withdrawal of premium for Surrender Charge purposes. See the Statement of Additional Information. Keep in mind that surrenders and withdrawals may be taxable and, if made before age 59½, may be subject to a 10% federal penalty tax. For tax purposes, surrenders and withdrawals from nonqualified policies are considered to come from taxable earnings first.

We may elect to reduce or eliminate the amount of the Surrender Charge when the Policy is sold under circumstances which reduce our sales or other expenses or when required to by regulation or regulatory authority.

If You take a withdrawal during the committed premium period and thereafter make additional premium payments during the committed premium period, we will calculate if a refund of Surrender Charges already paid is due. See Appendix - Premium Based Charges for an example of how the refund is calculated. If a refund is due it will be made pro rata into Your Investment Options. No interest will be paid in the refunded amount, nor will we be responsible for lost market opportunities.

Excess Interest Adjustment

Surrenders, withdrawals, transfers, amounts applied when a death benefit is calculated, and amounts applied to an annuity option from the Fixed Account may be subject to an Excess Interest Adjustment. This adjustment could retroactively reduce the interest credited in the Fixed Account to the guaranteed minimum or increase the amount credited. This adjustment may also apply to amounts applied to an Annuity Payment Option. However, please note that a death benefit will not be reduced if the Excess Interest Adjustment results in a decrease in the Cash Value available to You. Please see Appendix - Excess Interest Adjustment Examples for an example showing the effect of a hypothetical Excess Interest Adjustment calculation. The Excess Interest Adjustment plays a role in calculating the total interest credited to the Fixed Account.

Premium Taxes

A deduction is also made for premium taxes, if any, imposed on us by a state, municipality or other government agency. The tax, currently ranging from 0% to 3.50%, is assessed at the time premium payments are made or when annuity payments begin. We pay the premium tax at the time it is imposed. We will, at our discretion, deduct the total amount of premium taxes, if any, from the Policy Value when such taxes are due to the applicable taxing authority, You begin receiving annuity payments, You surrender the Policy or a death benefit is paid.

Federal, State and Local Taxes

We may in the future deduct charges from the Policy for any taxes we incur because of the Policy. However, no deductions are being made at the present time.

Special Service Fees

We currently deduct a charge for overnight delivery and duplicate policies. We reserve the right to deduct a charge for special services in the future, including non-sufficient checks on new business; duplicate Form 1099 and Form 5498 tax forms; check copies; printing and mailing previously submitted forms; and asset verification requests from mortgage companies. We may charge a fee for each service performed and fees may vary based on the type of service but will not exceed the maximum Special Service Fee shown in the Fee Table.

Transfer Fee

You are generally allowed to make 12 free transfers per Policy Year before the Annuity Commencement Date. If You make more than 12 transfers per Policy Year, we reserve the right to charge for each additional transfer. Premium payments, Asset Rebalancing, and Dollar Cost Averaging transfers do not count as one of Your free transfers. All transfer requests made at the same time are treated as a single transfer. Currently, we are not charging for transfers, but reserve the right to do so in the future.

Base Contract Expenses

Mortality and Expense Risk Fees

We charge a fee as compensation for bearing certain mortality and expense risks under the Policy. This fee is assessed daily based on the net asset value of each Subaccount. Examples of such risks include a guarantee of annuity rates, the death benefit, certain expenses of the Policy (including distribution related expenses), and assuming the risk that the current charges will be insufficient in the future to cover costs of selling, distributing and administering the Policy.

If this charge does not cover our actual costs, we absorb the loss. Conversely, if the charge more than covers actual costs, the excess is added to our surplus. We expect to profit from this charge. We may use any profit for any proper purpose, including distribution expenses.

Administrative Charges

We deduct a daily administrative charge to cover the costs of supporting and administering the Policy (including certain distribution-related expenses). This charge is equal to a percentage of the daily net asset value of each Subaccount during both the accumulation phase and the income phase.

Annual Service Charge

We reserve the right to increase the annual service charge up to the maximum. A portion of the service charge may be waived, but is not guaranteed to always be waived. We reserve the right to vary the amount of any waiver and the circumstances in which any waiver or waivers apply.

Fund Facilitation Fee

We charge a Fund Facilitation Fee in order to make certain Portfolio Companies available as Investment Options under the policies. We apply the fee to Portfolio Companies that invest in underlying fund portfolios that do not provide us with the amount of revenue we require in order for us to meet our expenses and revenue targets. This fee is assessed daily based on the net asset value of Portfolio Companies that we specify.

Optional Benefits

If You elect to purchase optional benefits, we will deduct an additional fee. For some optional benefits the fee is assessed against the daily net asset value of each Subaccount and for others it is deducted from each Investment Option in proportion to the amount of Policy Value in each Investment Option. Please refer to the ANNUITY POLICY FEE TABLE AND EXPENSE EXAMPLES for the list of fees for each optional benefit and Optional Benefit Riders section for more information.

Underlying Fund Portfolio Fees and Expenses

The value of the assets in each Subaccount will reflect the fees and expenses paid by the underlying Fund Portfolios. The lowest and highest Underlying Fund Portfolio expenses for the previous calendar year are found in ANNUITY POLICY FEE TABLE AND EXPENSE EXAMPLES in this prospectus. See the prospectuses for the Underlying Fund Portfolios for more information.

Reduced Fees and Charges

We may, at our discretion, reduce or eliminate certain fees and charges for certain policies (including employer-sponsored savings plans) which may result in decreased costs and expenses.

Revenue We Receive

This prospectus describes generally the payments that we (and/or our affiliates) may directly or indirectly receive from the underlying fund portfolios, their advisers, sub-advisers, distributors or affiliates thereof, in connection with certain administrative, marketing and other support services we (and/or our affiliates) provide and expenses we incur in offering and selling our variable insurance products. These arrangements are described further below. While only certain of the types of payments described below may be made in connection with Your particular Policy, all such payments may nonetheless influence or impact actions we (and/or our affiliates) take, and recommendations we (and our affiliates) make, regarding each of the variable insurance products that we (and our affiliates) offer, including Your Policy.

We (and/or our affiliates) may receive some or all of the following types of payments:

● Rule 12b-1 Fees. We and/or our affiliate, Transamerica Capital, Inc. (“TCI” ) who is the principal underwriter for the policies, indirectly receive 12b-1 fees from certain underlying fund portfolios available as Investment Options under our variable insurance products. Any 12b-1 fees received by TCI that are attributable to our variable insurance products are then credited to us. These fees range from 0.00% to 0.45% of the average daily assets of the certain underlying fund portfolios attributable to the policies and to certain other variable insurance products that we and our affiliates issue. These fees are paid from the underlying fund portfolios’ assets. Policy Owners, through their indirect investment in the underlying fund portfolios, bear the costs of 12b-1 fees (see the prospectuses for the underlying fund portfolios for more information).

● Administrative, Marketing and Support Service Fees (“Support Fees”). As noted above, an investment adviser, sub-adviser, administrator and/or distributor (or affiliates thereof) of the underlying fund portfolios may make payments to us and/or our affiliates, including TCI. These payments may be derived, in whole or in part, from the profits the investment adviser or sub-adviser realized on the advisory fee deducted from underlying fund portfolio assets. Policy Owners, through their indirect investment in the underlying fund portfolios, bear the costs of these advisory fees (see the prospectuses for the underlying fund portfolios for more information). The amount of the payments we (or our affiliates) receive is generally based on a percentage of the assets of the particular underlying fund portfolios attributable to the Policy and to certain other variable insurance products that our affiliates and we issue. These percentages differ and the amounts may be significant. Some advisers or sub-advisers (or other affiliates) pay us more than others.

The following chart provides the maximum combined percentages of Support Fees and underlying fund portfolio fees (i.e. sub-transfer agent, Rule 12b-1, and Shareholder Services) that we anticipate will be paid to us on an annual basis.

Incoming Payments to Us and/or TCI
Underlying Fund Portfolio	Maximum Fee % of assets
TRANSAMERICA SERIES TRUST (“TST”)	0.25%
AB VARIABLE PRODUCTS SERIES FUND, INC.	0.45%
AMERICAN FUNDS INSURANCE SERIES® TRUST	0.25%
FIDELITY® VARIABLE INSURANCE PRODUCTS FUND	0.395%
STATE STREET VARIABLE INSURANCE SERIES FUNDS, INC.	0.45%

NOTES TO INCOMING PAYMENTS TABLE:

Maximum Fee % of assets: Payments are based on a percentage of the average assets of each underlying fund portfolio owned by the Subaccounts available under this Policy and under certain other variable insurance products offered by our affiliates and us. We and/or TCI may continue to receive 12b-1 fees and administrative fees on assets invested in Subaccounts that are closed to new premium payments, depending on the terms of the agreements supporting those payments and on the services provided.

TST: Because TST is managed by TAM, an affiliate of ours, there are additional benefits to us and our affiliates for amounts You allocate to the TST underlying fund portfolios, in terms of our and our affiliates’ overall profitability. These additional benefits may be significant. Payments or other benefits may be received from TAM. Such payments or benefits may be entered into for a variety of purposes, such as to allocate resources to us and to provide administrative services to the policyholders who invest in Subaccounts that invest in the TST underlying fund portfolios. These payments or benefits may take the form of internal credits, recognition, or cash payments. A variety of financial and accounting methods may be used to allocate resources and profits to us. Additionally, if a TST portfolio is sub-advised by an entity that is affiliated with us, we may retain more revenue than on those TST portfolios that are sub-advised by non-affiliated entities. During 2023 we received approximately $174.1 million for

Transamerica Life Insurance Company and $12.3 million for Transamerica Financial Life Insurance Company in benefits from TAM pursuant to these arrangements. This includes the 0.25% amount in the above chart. We anticipate that the amounts will decline in 2023.

Fidelity® Variable Insurance Products Fund: We receive this percentage once $100 million in shares are held by the Subaccounts of ours and our affiliates.

Other Payments. TCI also serves as the wholesale distributor for the policies, and in that capacity directly or indirectly receives additional amounts or different percentages of assets under management from certain advisers and sub-advisers to the underlying fund portfolios (or their affiliates) with regard to variable insurance products and/or mutual funds that are issued by us and our affiliates. These amounts may be derived, in whole or in part, from the profits the investment adviser or sub-adviser receives from the advisory fee deducted from underlying fund portfolio assets. Owners, through their indirect investment in the underlying fund portfolios, bear the costs of these advisory fees. Certain advisers and sub-advisers of the underlying fund portfolios (or their affiliates):

●

may directly or indirectly pay TCI conference sponsorship or marketing allowance payments that provides such advisers and sub-advisers with access to TCI's wholesalers at TCI's national and regional sales conferences as well as internal and external meetings and events that are attended by TCI's wholesalers and/or other TCI employees.

●

may provide our affiliates and/or selling firms with wholesaling services to assist us in the distribution of the policies.

●

may provide us and/or certain affiliates and/or selling firms with occasional gifts, meals, tickets or other compensation as an incentive to market the underlying fund portfolios and to assist with their promotional efforts. The amounts may be significant and these arrangements provide the adviser or sub-adviser (or other affiliates) with increased access to us and to our affiliates involved in the distribution of the policies.

For the calendar year ended December 31, 2023, TCI and its affiliates received revenue sharing payments from asset managers including Rothschild ● Thompson Siegel and Walmsley ● Aegon Asset Managment ● BlackRock ● Fidelity Investments ● Franklin Templeton ● J.P. Morgan Asset Management ● Janus Henderson ● Madison Investments ● Milliman Financial Risk Management ● PGIM Quantitative Solutions ● PineBridge ● Systematic Financial ● Wellington ● PIMCO ● T. Rowe Price and Goldman Sachs in the amount of $550,000.00 to participate in TCI sponsored events.

Please note some of the aforementioned managers and/or sub-advisers may not be associated with underlying fund portfolios currently available in this product.

Proceeds from certain of these payments by the underlying fund portfolios, the advisers, the sub-advisers and/or their affiliates may be used for any corporate purpose, including payment of expenses (1) that we and our affiliates incur in promoting, marketing, and administering the Policy, and (2) that we incur, in our role as intermediary, in promoting, marketing, and administering the underlying fund portfolios. We and our affiliates may profit from these payments.

For further details about the compensation payments we make in connection with the sale of the policies, see OTHER INFORMATION - Distribution of the Policies in this prospectus.

general description of the policy

Ownership

You, as Owner of the Policy, exercise all rights under the Policy. You can generally change the Owner at any time by notifying us in writing at our Administrative Office. If we do not have an originating signature or guaranteed signature on file or if the Company suspects fraud, we may require a notarized signature. There may be limitations on Your ability to change the ownership of a qualified Policy. An ownership change may be a taxable event.

Beneficiary

The beneficiary designation will remain in effect until changed. The Owner may change the designated beneficiary by sending us Written Notice. The beneficiary's consent to such change is not required unless the beneficiary was irrevocably designated or law requires consent. (If an irrevocable beneficiary dies, the Owner may then designate a new beneficiary.) We will not be liable for any payment made before the Written Notice is received in our Administrative Office. If more than one beneficiary is designated, and the Owner fails to specify their interests, they will share equally. If, upon the death of the Annuitant, there is a surviving Owner (s), then the surviving Owner (s) automatically takes the place of any beneficiary designation.

Assignment

You can also generally assign the Policy any time during Your lifetime. We will not be bound by the assignment until we receive Written Notice of the assignment in good order at our Administrative Office and approve it. We reserve the right, except to the extent prohibited by applicable laws, regulations, or actions of the State insurance commissioner, to require that an assignment will be

effective only upon acceptance by us, and to refuse assignments or transfers at any time on a non-discriminatory basis. We will not be liable for any payment or other action we take in accordance with the Policy before we approve the assignment. There may be limitations on Your ability to assign a qualified Policy. An assignment may have tax consequences.

Termination for Low Value

If a withdrawal or fee (including an optional rider fee, administrative fee, or Owner transaction fee) reduces Your Cash Value below the minimum specified in Your Policy, we reserve the right to terminate Your Policy and send You a full distribution of Your remaining Cash Value. All benefits associated with Your annuity Policy will be terminated. Federal law may impose restrictions on our right to terminate certain qualified policies. We do not currently anticipate exercising this right if You have certain optional benefits, however, we reserve the right to do so.

Certain Offers

From time to time, we have (and we may again) offered You some form of payment or incentive in return for terminating or modifying certain guaranteed benefits.

When we make an offer, we may vary the offer amount, up or down, among the same group of Policy Owners based on certain criteria such as account value, the difference between account value and any applicable benefit base, investment allocations and the amount and type of withdrawals taken. For example, for guaranteed benefits that have benefit bases that can be reduced on either a pro rata or dollar-for-dollar basis depending on the amount of withdrawals taken, we may consider whether You have taken any withdrawal that has caused a pro rata reduction in Your benefit base, as opposed to a dollar-for-dollar reduction. Also, we may increase or decrease offer amounts from offer to offer. In other words, we may make an offer to a group of Policy Owners based on an offer amount, and, in the future, make another offer based on a higher or lower offer amount to the remaining Policy Owners in the same group.

If You accept an offer that requires You to terminate a guaranteed benefit and You retain Your Policy, we will no longer charge You for the benefit, and You will not be eligible for any future offers related to that type of guaranteed benefit, even if such future offer would have included a greater offer amount or different payment or incentive.

We may also make an offer to You to exchange an existing rider for a different rider.

Exchanges and/or Reinstatements

You can generally exchange a nonqualified annuity Policy for another in a “tax-free exchange” under Section 1035 of the Internal Revenue Code or transfer qualified policies directly to another life insurance company as a “trustee-to-trustee transfer”. Before making an exchange or transfer, You should compare both annuities carefully. Remember that if You exchange or transfer another annuity for the one described in this prospectus, then You may pay a surrender charge on the other annuity, and there may be a new surrender charge period under this annuity and other charges may be higher (or lower) and the benefits under this annuity may be different. You should not exchange or transfer another annuity for this one unless You determine, after knowing all the facts, that the exchange or transfer is in Your best interest and not just better for the person trying to sell You this Policy (that person will generally earn a commission if You buy this Policy through an exchange, transfer or otherwise).

You may ask us to reinstate Your Policy after such an exchange, transfer, withdrawal or surrender and in certain limited circumstances we will allow You to do so by returning the same total dollar amount of funds distributed to the applicable Investment Options. The dollar amount will be used to purchase new Accumulation Units at the then current price. In the event any Subaccount previously invested in is closed and we don’t receive additional instructions, funds will be reallocated to the remaining available Investment Options according to the investment allocation instructions You previously provided. Because of changes in market value, Your new Accumulation Units may be worth more or less than the units You previously owned. Generally for non-qualified annuity reinstatements, unless You return the original company check, if a portion of the prior withdrawal was taxable, we are required to report the taxable amount from the distribution even though the funds have been reinstated. The cost basis will be adjusted accordingly. The taxable amount will be reported on Form 1099-R which You will receive in January of the year following the distribution. Qualified annuity reinstatements may be subject to the same tax reporting and rollover requirements. We recommend that You consult a tax professional to explain the possible tax consequences of reinstatements.

ACCESS TO YOUR MONEY

During the accumulation phase, You can have access to the money in Your Policy in the following ways:

●

by making a surrender or withdrawal; or

●

by taking systematic payouts (See ADDITIONAL FEATURES - Systematic Payout Option for more details).

Surrenders and Withdrawals

During the accumulation phase, if You take a full surrender You will receive Your Cash Value. If You want to take a withdrawal, in most cases it must be for at least $500. Certain optional benefits have specific requirements regarding the order in which surrenders can be taken from Investment Options. Unless You tell us otherwise, we will take the withdrawal from each of the Investment Options in proportion to the Policy Value. Surrenders may be referred to as withdrawals on Your Policy statement and other documents.

You may elect to take up to the Surrender Charge Free Amount each Policy Year without incurring a surrender charge.Remember that any withdrawal You take will reduce the Policy Value, and the amount of the death benefit. See DEATH BENEFIT, for more details. A withdrawal also may have a negative impact on certain other benefits and guarantees of Your Policy. See ADDITIONAL FEATURES, for more details.

Withdrawals in excess of the Surrender Charge Free Amount may be subject to a surrender charge. Withdrawals from the Fixed Account may be subject to an Excess Interest Adjustment. Income taxes, federal tax penalties and certain restrictions may apply to any withdrawals You make.

Please note: If a withdrawal would result in Your Policy Value immediately after the withdrawal being equal to or less than the total remaining Premium Based Charges, we reserve the right to treat Your withdrawal request as a surrender request, assess a surrender charge equal to all remaining Premium Based Charges, pay You Your Cash Value and terminate Your Policy. We will not exercise this right if at the time of the withdrawal You have the Retirement Income Choice® 2.0 rider or the Retirement Income Max® 2.0 rider and the amount of Your withdrawal does not exceed the remaining rider withdrawal amount for that rider year.

Withdrawals from qualified policies may be restricted or prohibited.

During the income phase, You will receive annuity payments under the Annuity Payment Option You select; however, You generally may not take any other surrenders or withdrawals.

Delay of Payment and Transfer

Payment of any amount due from the Separate Account for a surrender, a death benefit, or the death of the Owner of a nonqualified Policy, will generally occur within seven days from the date we receive in good order all required information at our Administrative Office. We may defer such payment from the Separate Account if:

●

the New York Stock Exchange is closed other than for usual weekends or holidays or trading on the Exchange is otherwise restricted;

●

an emergency exists as defined by the SEC or the SEC requires that trading be restricted; or

●

the SEC permits a delay for the protection of Owners.

Transfers of amounts from the Subaccounts also may be deferred under these circumstances. In addition, if, pursuant to SEC rules, the Transamerica BlackRock Government Money Market VP portfolio (or any money market portfolio offered under this Policy) suspends payment of redemption proceeds in connection with a liquidation of the portfolio, then we may delay payment of any transfer, surrender, withdrawal, loan, or death benefit from the TA BlackRock Government Money Market Subaccount until the portfolio is liquidated.

Any payment or transfer request which is not in good order will cause a delay. See OTHER INFORMATION - Sending Forms and Transaction Requests in Good Order.

Pursuant to the requirements of certain state laws, we reserve the right to defer payment of the Cash Value from the Fixed Account for up to six months. We may defer payment of any amount until Your premium payment check has cleared Your bank.

Excess Interest Adjustment

Surrenders, withdrawals, transfers, and amounts applied to an annuity option, from a Guaranteed Period Option of the Fixed Account before the end of its guaranteed period (the number of years You specified the money would remain in the Guaranteed Period Option) may be subject to an Excess Interest Adjustment. If, at the time of such transactions the guaranteed interest rate set by us for the applicable period has risen since the date of the initial guarantee, the Excess Interest Adjustment will result in a lower Cash Value (but not below the Excess Interest Adjustment floor described in Appendix - Excess Interest Adjustment Examples). However, if the guaranteed interest rate for the applicable period has fallen since the date of the initial guarantee, the Excess Interest Adjustment will result in a higher Cash Value upon withdrawal, surrender or transfer. Please see Appendix - Excess Interest Adjustment Examples to see how the Excess Interest Adjustment is calculated and illustrative examples using hypothetical values.

Any amount withdrawn in excess of the cumulative interest credited for that Guaranteed Period Option is generally subject to an Excess Interest Adjustment. An Excess Interest Adjustment may also be made on amounts applied to an Annuity Payment Option.

The formula that will be used to determine the Excess Interest Adjustment is:

S* (G-C)* (M/12)
S	=	Is the amount (before surrender charges, premium taxes and the application of any Guaranteed Minimum Death Benefits, if any) being surrendered, withdrawn, transferred, paid upon death, or applied to an income option that is subject to the Excess Interest Adjustment;
G	=	Is the guaranteed interest rate for the guaranteed period applicable to “S”;
C	=	Is the current guaranteed interest rate then being offered on new premium payments for the next longer option period than “M”. If this Policy form or such an option period is no longer offered, “C” will be the U.S. Treasury rate for the next longer maturity (in whole years) than “M” on the 25th day of the previous calendar month,
M	=	Number of months remaining in the current option period for “S”, rounded up to the next higher whole number of months; and
*	=	Multiplication

Please see Appendix - Excess Interest Adjustment Examples for more detailed information concerning the Excess Interest Adjustment calculation.

There will be no Excess Interest Adjustment on any of the following:

●

withdrawals or transfers of cumulative interest credited for that Guaranteed Period Option;

●

Nursing Care and Terminal Condition Waiver surrenders;

●

Unemployment Waiver withdrawals;

●

transfers from a Dollar Cost Averaging fixed source;

●

withdrawals to satisfy any minimum distribution requirements;

●

systematic withdrawals, which do not exceed cumulative interest credited at the time of payment; and

●

the Stable Account as defined in the glossary.

Please note that in these circumstances You will not receive a higher Cash Value if interest rates have fallen nor will You receive a lower Cash Value if interest rates have risen.

The Excess Interest Adjustment may not be applicable for all policies.

Signature Guarantee

As a protection against fraud, we require a signature guarantee (i.e., Medallion Signature Guarantee as required by us) for the following transaction requests:

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Any withdrawals or surrenders over $250,000 unless it is a custodial owned annuity;

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Any non-electronic disbursement request made on or within 15 days of a change to the address of record for the Policy Owner’s account;

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Any electronic fund transfer instruction changes on or within 15 days of an address change;

●

Any withdrawal or surrender when we have been directed to send proceeds to a different personal address from the address of record for that Owner. PLEASE NOTE: This requirement will not apply to requests made in connection with exchanges of one annuity for another with the same Owner in a “tax-free exchange”;

●

Any withdrawal or surrender when we do not have an originating or guaranteed signature on file unless it is a custodial owned annuity;

●

Any other transaction we require.

We may change the specific requirements listed above, or add signature guarantees in other circumstances, at our discretion if we deem it necessary or appropriate to help protect against fraud. For current requirements, please refer to the requirements listed on the appropriate form or call us at (800)525-6205.

You can obtain a Medallion signature guarantee from more than 7,000 financial institutions across the United States and Canada that participate in a Medallion signature guarantee program. The best source of a Medallion signature guarantee is a bank, savings and loan association, brokerage firm, or credit union with which You do business. A notary public cannot provide a Medallion signature guarantee. Notarization will not substitute for a Medallion signature guarantee.

ANNUITY PAYMENTS (THE INCOME PHASE)

Upon the Annuity Commencement Date, which is the date Your Policy is Annuitized and annuity payments begin, Your annuity switches from the accumulation phase to the income phase. You can generally change the Annuity Commencement Date by giving us 30 days notice with the new date or age. Unless required by state law this date cannot be earlier than the third Policy anniversary. The latest Annuity Commencement Date generally cannot be later than the last day of the month following the month in which the Annuitant attains age 99 (earlier if required by state law).

Before the Annuity Commencement Date, if the Annuitant is alive, You may choose an Annuity Payment Option or change Your election. If the Annuitant dies before the Annuity Commencement Date, the death benefit is payable in a lump sum or under one of the Annuity Payment Options (unless the surviving spouse is eligible to and elects to continue the Policy). If the Annuitant dies after the Annuity Commencement Date, no death benefit is payable and any remaining guaranteed payment will be paid to the beneficiary as provided for in the annuity income option elected.

Your Policy may not be “partially” Annuitized, i.e., You may not apply a portion of Your Policy Value to an annuity option while keeping the remainder of Your Policy in force.

Unless You specify otherwise, the Owner will receive the annuity payments. After the Annuitant's death, the beneficiary You designate at Annuitization will receive any remaining guaranteed payments.

Annuity Payment Options

The Policy provides several Annuity Payment Options (also known as income options) that are described below. You may choose any combination of Annuity Payment Options. We will use Your Adjusted Policy Value to provide these annuity payments. If the Adjusted Policy Value on the Annuity Commencement Date is less than $2,000, we reserve the right to pay it in one lump sum in lieu of applying it under an Annuity Payment Option. You can receive annuity payments monthly, quarterly, semi-annually, or annually. (We reserve the right to change the frequency if annuity payments would be less than the amount specified in Your Policy.) We may require proof of life before making annuity payments.

In deciding on which Annuity Payment Option to elect, You must decide if fixed or variable payments are better for You. If You choose to receive fixed annuity payments, then the amount of each payment will be set on the Annuity Commencement Date and will not change. You may, however, choose to receive variable annuity payments. The dollar amount of the first variable annuity payment will be determined in accordance with the annuity payment rates set forth in the applicable table contained in the Policy. The dollar amount of additional variable annuity payments will vary based on the investment performance of the Subaccount(s) You select. The dollar amount of each variable annuity payment after the first may increase, decrease, or remain constant. If the actual investment performance (net of fees and expenses) exactly matched the Assumed Investment Return of 3% at all times, the amount of each variable annuity payment would remain constant. If actual investment performance (net of fees and expenses) exceeds the Assumed Investment Return, the amount of the variable annuity payments would increase.

For example, assume the first monthly variable annuity payment is $500.00, further assume that the investment performance for the 1st month is an 8.00% annual rate of return, then the second monthly variable annuity payment would increase to $501.37. Conversely, if actual investment performance (net of fees and expenses) is lower than the Assumed Investment Return, the amount of the variable annuity payments would decrease. Continuing from the previous example, further assume that the investment performance for the 2nd month is a -2.00% annual rate of return, then the 3rd monthly variable payment would decrease to $498.88.

You must also decide if You want Your annuity payments to be guaranteed for the Annuitant's lifetime, a period certain, or a combination thereof. Generally, annuity payments will be lower if You combine a period certain, guaranteed amount, or liquidity with a lifetime guarantee (e.g., Life Income with 10 years Certain and Life with Guaranteed Return of Policy proceeds). Likewise, annuity payments will also generally be lower the longer the period certain (because You are guaranteed payments for a longer time).

A charge for premium taxes and an Excess Interest Adjustment may be made when annuity payments begin.

The Annuity Payment Options currently available are explained below. Some options are fixed only.

Income for a Specified Period (fixed only). We will make level annuity payments only for a fixed period. No assets will remain at the end of the period. If Your Policy is a qualified Policy, this Annuity Payment Option may not satisfy minimum required distribution rules. Consult a financial professional before electing this option.

Income of a Specified Amount (fixed only). Payments are made for any specified amount until the amount applied to this option, with interest, is exhausted. This will be a series of level annuity payments followed by a smaller final annuity payment. If Your Policy is a qualified Policy, this Annuity Payment Option may not satisfy minimum required distribution rules. Consult a financial professional before electing this option.

Life Income. You may choose between:

●

No Period Certain (fixed or variable) - Payments will be made only during the Annuitant's lifetime. The last annuity payment will be the payment immediately before the Annuitant's death. If You choose this option and the Annuitant dies before the due date of the first annuity payment no payments will be made.

●

10 Years Certain (fixed or variable) - Payments will be made for the longer of the Annuitant's lifetime or ten years.

●

Guaranteed Return of Policy Proceeds (fixed only) - Payments will be made for the longer of the Annuitant's lifetime or until the total dollar amount of annuity payments we made to You equals the Annuitized amount (i.e., the Adjusted Policy Value less premium tax, if applicable).

Joint and Survivor Annuity. You may choose:

●

No Period Certain (fixed or variable) - Payments are made during the joint lifetime of the Annuitant and a joint Annuitant of Your selection. Annuity payments will be made as long as either person is living. If You choose this option and both joint Annuitants die before the due date of the first annuity payment no payments will be made.

●

10 Year Certain (fixed only) - Payments will be made for the longer of the lifetime of the Annuitant and joint Annuitant or ten years.

Other Annuity Payment Options may be arranged by agreement with us. Some Annuity Payment Options may not be available for all policies, all ages or we may limit certain Annuity Payment Options to ensure they comply with the applicable tax law provisions.

NOTE CAREFULLY

IF:

●

You choose Life Income with No Period Certain or a Joint and Survivor Annuity with No Period Certain; and

●

the Annuitant dies (or both joint Annuitants die) before the due date of the second (third, fourth, etc.) annuity payment;

THEN:

●

we may make only one (two, three, etc.) annuity payments.

IF:

●

You choose Income for a Specified Period, Life Income with 10 Years Certain, Life Income with Guaranteed Return of Policy Proceeds, or Income of a Specified Amount; and

●

the person receiving annuity payments dies prior to the end of the guaranteed period;

THEN:

●

the remaining guaranteed annuity payments will be continued to a new payee, or their present value may be paid in a single sum.

We will not pay interest on amounts represented by uncashed annuity payment checks if the postal or other delivery service is unable to deliver checks to the payee's address of record. The person receiving annuity payments is responsible for keeping us informed of his/her current address.

You must Annuitize Your Policy no later than the maximum Annuity Commencement Date specified in Your Policy (earlier for certain distribution channels) or a later date if agreed to by us. If You do not elect an Annuity Payment Option, the default option will be variable payments under Life with 10 Years Certain. If any portion of the default Annuitization is a variable payout option, then annuity units will be purchased proportionally based off Your available current investment allocations. Please note, all benefits (including guaranteed minimum death benefits and living benefits) terminate upon Annuitization. The only benefits that remain include the guarantees provided under the terms of the annuity option.

Please Note: If You Annuitize before the maximum Annuity Commencement Date, the payments You receive under the Annuity Payment Options may be less than the guaranteed minimum payments You are entitled to under a GLWB rider (if elected). Please consult Your financial professional about the advisability of Annuitization before the maximum commencement date and the Annuity Payment options available to You.

Benefits Available Under the Policy

The following table summarizes information about the benefits available under the Policy.

Name of Benefit	Purpose	Standard or Optional	Maximum Annual Fee	Brief Description of Restrictions/Limitations
“Base Policy” Death Benefit	Pays base death benefit generally equal to the greatest of Policy Value, Cash Value plus positive Excess Interest Adjustment and Fixed Account portion of minimum required Cash Value plus the Separate Account portion of the Policy Value.	Standard	No Charge	●Available only at time of purchase. ●Cannot change death benefit once elected. ●Death benefit terminates without value upon Annuitization. ●May not be available in all states.
Return of Premium Death Benefit	Pays minimum death benefit equal to total premium payments (minus adjusted withdrawals as of the date of death, and minus withdrawals from the date of death to the date the death benefit is paid).	Optional	0.15% annually of average Separate Account Value	●Available only at time of purchase. ●Cannot change death benefit once elected. ●Not available if You or Annuitant is 86 or older on Policy Date. ●Must allocate 100% of Policy Value to designated Investment Options. ●Withdrawals can significantly reduce benefit value or terminate benefit. ●Terminates upon Annuitization. ●May not be available in all states.

Name of Benefit	Purpose	Standard or Optional	Maximum Annual Fee	Brief Description of Restrictions/Limitations
Annual Step-Up Death Benefit	Pays death benefit equal to highest Policy Value on Policy Date or on any Policy Anniversary prior to Annuitant’s 81st birthday (adjusted for premium payments and withdrawals).	Optional	0.35% annually of average Separate Account Value	●Available only at time of purchase. ●Cannot change death benefit once elected. ●Not available if You or Annuitant is 76 or older on Policy Date. ●Must allocate 100% of Policy Value to designated Investment Options. ●Withdrawals can significantly reduce benefit value or terminate benefit. ●”Step-Up” ends on Policy Anniversary prior to Your 81st birthday. ●Terminates upon Annuitization. ●May not be available in all states.
Additional Death DistributionSM	Pays an additional death benefit amount based on any rider earnings, since the rider was issued.	Optional	0.25% annually of the Policy Value.	●This rider is no longer available. ●Was available for issue ages through 75 and younger. ●Was not available to Inherited IRAs. ●Was available only with Return of Premium Death Benefit or Annual Step-Up Death Benefit and subject to the same Investment Restrictions ●Additional benefit amount varies by issue age. ●Terminates upon Annuitization.

Name of Benefit	Purpose	Standard or Optional	Maximum Annual Fee	Brief Description of Restrictions/Limitations
Additional Death Distribution+SM	Pays an additional death benefit amount that varies depending on time elapsed since rider date.	Optional	0.55% annually of the Policy Value	●This rider is no longer available. ●Was available only for issue ages 69 and younger. ●Not available to Inherited IRAs. ●Was available only with the Return of Premium Death Benefit or Annual Step-Up Death Benefit, and subject to the same Investment Restrictions. ●Additional benefit amount during first five years after rider date equal to sum of all rider fees paid since rider date, after five years, benefit equal to percentage of rider benefit base. ●Terminates upon Annuitization.
Nursing Care and Terminal Condition Waiver	Waives Surrender Charges and Excess Interest Adjustments if You or Your spouse are confined to a nursing home or have terminal illness.	Standard	No charge	●Withdrawals are subject to a $1,000 minimum. ●Qualifying conditions related to nursing home stay and terminal illness. ●May not be available in all states.
Unemployment Waiver	Waives Surrender Charges and Excess Interest Adjustments if You or Your spouse become unemployed due to involuntary job termination or lay-off.	Standard	No charge	●Qualifying conditions related to job termination and job history. ●Must be unemployed for a certain period of time prior to taking withdrawal, be receiving unemployment benefits, and have $5,000 minimum in Cash Value. ●May not be available in all states.

Name of Benefit	Purpose	Standard or Optional	Maximum Annual Fee	Brief Description of Restrictions/Limitations
Retirement Income Choice 1.6 Rider	Provides Guaranteed Lifetime Withdrawal Benefit amount, which can be withdrawn in any rider year after age 59. Also provides death protection and/or long-term care benefit for an additional fee.	Optional	2.20% annually of the Withdrawal Base (riders issued on or after May 1, 2017) Income Enhancement Option: 0.45% annually (Single Life) or 0.65% annually (Joint Life) of Withdrawal Base	●This rider is no longer available. ●Could not be added to a Policy with another active Guaranteed Minimum Living Benefit or with Inherited IRA policies. ●Was available for Owner/Annuitant issue ages of 0-85. ●Joint Life options available subject to certain restrictions and differences, including right to charge higher fee and provide lower annual withdrawal amounts. ●Rider fees subject to increase (or decrease) at time of any automatic step-up beginning on the 5th rider anniversary. ●Policy Value must be allocated to designated Investment Options. ●Excess withdrawals could significantly reduce or terminate the benefits. ●The Income Enhancement Option subject to qualifying conditions, including conditions related to the hospital and/or nursing home stay.

Name of Benefit	Purpose	Standard or Optional	Maximum Annual Fee	Brief Description of Restrictions/Limitations
Transamerica Income EdgeSM Rider	Provides Guaranteed Lifetime Withdrawal Benefit amount, which can be withdrawn in any rider year after age 59.	Optional	2.50% annually of Withdrawal Base (for rider issued on or after May 1, 2017)	●This rider is no longer available. ●Could not be added to a Policy with another active Guaranteed Minimum Living Benefit or Guaranteed Minimum Income Benefit Rider, or with Inherited IRA policies. ●Was available for Owner/Annuitant issue ages of 0-85. ●Joint Life options available subject to certain restrictions and differences, including right to charge higher fee and provide lower annual withdrawal amounts. ●Rider fees subject to increase (or decrease) at time of any automatic step-up. ●Policy Value must be allocated to designated Investment Options. ●Excess withdrawals could significantly reduce or terminate the benefits.

DEATH BENEFIT

We will pay a death benefit to Your beneficiary, under certain circumstances, if the Annuitant dies during the accumulation phase. If there is a surviving Owner(s) when the Annuitant dies, the surviving Owner(s) will receive the death benefit instead of the listed beneficiary. The person receiving the death benefit may choose an Annuity Payment Option (if You pick a variable Annuity Payment Option fees and expenses will apply), or may choose to receive the death benefit as a lump sum withdrawal. The guarantees of these death benefits are based on our claims-paying ability. No death benefit will be payable upon or after the Annuity Commencement Date. Please note that there is a mandatory Annuity Commencement Date. See ANNUITY PAYMENTS (THE INCOME PHASE) section in this prospectus.

We will determine the amount of and process the death benefit proceeds, if any are payable on a Policy, upon receipt at our Administrative Office of satisfactory proof of the Annuitant's death, directions regarding how to process the death benefit, and any other documents, forms and information that we need (collectively referred to as “due proof of death”). For policies with multiple beneficiaries, we will process the death benefit when the first beneficiary provides us with due proof of their share of the Death Proceeds. We will not pay any remaining beneficiary their share until we receive due proof of death from that beneficiary. Such beneficiaries continue to bear the investment risk until they submit due proof of death. Please note, we may be required to remit the death benefit proceeds to a state prior to receiving “due proof of death”. See Abandoned or Unclaimed Property.

Please Note: Such due proof of death must be received in good order to avoid a delay in processing the death benefit claim. See OTHER INFORMATION - Sending Forms and Transaction Requests in Good Order.

The death benefit proceeds remain invested in the Separate Account in accordance with the allocations made by the Policy Owner until the beneficiary has provided us with due proof of death. Once we receive due proof of death, investments in the Separate Account may be reallocated in accordance with the beneficiary's instructions.

We may permit the beneficiary to give a “one-time” written instruction to reallocate the Policy Value in the Separate Account to the money market Subaccount after the death of the Annuitant. If there is more than one beneficiary, all beneficiaries must agree to the reallocation instructions. This one-time reallocation will be permitted if the beneficiary provides satisfactory evidence of the Annuitant's death (satisfactory evidence may include a certified death certificate).

When We Pay A Death Benefit

We will pay a death benefit IF:

●

You are both the Annuitant and sole Owner of the Policy; and

●

You die before the Annuity Commencement Date.

We will pay a death benefit to You (Owner) IF:

●

You are not the Annuitant; and

●

the Annuitant dies before the Annuity Commencement Date.

Please note: If there is a surviving Owner(s) when the Annuitant dies, the surviving Owner(s) will receive the death benefit (i.e., the surviving Owner(s) takes the place of any beneficiary designation).

If the designated beneficiary receiving the death benefit is the surviving spouse of the Owner, then he or she may elect, if eligible, to continue the Policy as the new Annuitant and Owner, instead of receiving the death benefit. See DEATH BENEFIT - Spousal Continuation. All currently existing surrender charges will be waived.

When We Do Not Pay A Death Benefit

We will not pay a death benefit IF:

●

You are the Owner but not the Annuitant; and

●

You die prior to the Annuity Commencement Date.

Please note: If an Owner (who is not the Annuitant) dies before the Annuitant, the amount payable will be equal to the Cash Value. Distribution requirements apply upon the death of any Owner. Generally, upon the Owner's death (who is not the Annuitant) the entire interest must be distributed in accordance with the Internal Revenue Code. See TAX INFORMATION for a more detailed discussion of the distribution requirements under the Code.

If an Owner (who is not the Annuitant) dies during the accumulation phase, the Cash Value will be paid to the person or entity first listed below who is alive or in existence on the date of that death:

●

any surviving Owner(s);

●

primary beneficiary(ies);

●

contingent beneficiary(ies); or

●

deceased Owner's estate.

Deaths After the Annuity Commencement Date

The amount payable, if any, on or after the Annuity Commencement Date depends on the annuity income option.

IF:

●

You are not the Annuitant; and

●

You die on or after the Annuity Commencement Date; and

●

the entire guaranteed amount in the Policy has not been paid;

THEN:

●

the remaining portion of such guaranteed amount in the Policy will continue to be distributed at least as rapidly as under the method of distribution being used as of the date of Your death.

IF:

●

You are the Owner and Annuitant; and

●

You die after the Annuity Commencement Date; and

●

the Annuity Payment Option You selected did not have or no longer has a guaranteed period;

THEN:

●

no additional payments will be made.

Owner Death

●

any surviving Owner(s);

●

primary beneficiary(ies);

●

contingent beneficiary(ies); or

●

deceased Owner's estate.

Spousal Continuation

If the sole primary beneficiary is the spouse of the deceased, upon the Owner's or the Annuitant's death, the beneficiary may elect to continue the Policy in his or her own name. Upon the Annuitant's death if such election is made, the Policy Value will be adjusted upward (but not downward) to an amount equal to the death benefit amount determined upon such election and receipt of due proof of death of the Annuitant. Any excess of the death benefit amount over the Policy Value will be allocated to each applicable Investment Option in the ratio that the Policy Value in the Investment Option bears to the total Policy Value. The terms and conditions of the Policy that applied prior to the Annuitant's death will continue to apply, with certain exceptions described in the Policy. For purposes of the death benefit on the continued Policy, the death benefit is calculated in the same manner as it was prior to continuation on the date the spouse continues the Policy. See TAX INFORMATION - Same Sex Relationships for more information concerning spousal continuation involving same sex spouses.

For these purposes, if the sole primary beneficiary of the Policy is a revocable grantor trust and the spouse of the Owner/Annuitant is the sole grantor, trustee, and beneficiary of the trust and the trust is using the spouse of the Owner/Annuitant's social security number at the time of claim, she or he shall be treated as the Owner/Annuitant's spouse. In those circumstances, the Owner/Annuitant's spouse will be treated as the beneficiary of the Policy for purposes of applying the spousal continuation provisions of the Policy.

For these purposes, if the Owner is an individual retirement account within the meaning of IRC sections 408 or 408A and if the Annuitant's spouse is the sole primary beneficiary of the Annuitant's interest in such account, the Annuitant's spouse will be treated as the beneficiary of the Policy for purposes of applying the spousal continuation provisions of the Policy.

Amount of Death Benefit

Death benefit provisions may differ from state to state. The death benefit may be paid as a lump sum, as annuity payments or as otherwise permitted by the Company in accordance with applicable law. The amount of the death benefit depends on the guaranteed minimum death benefit option, if any, You choose when You buy the Policy. The “base Policy” death benefit will generally be the greatest of:

●

the Policy Value on the date we receive the required information in good order at our Administrative Office;

●

the Cash Value on the date we receive in good order the required information at our Administrative Office (this will be more than the Policy Value if there is a positive Excess Interest Adjustment that exceeds the surrender charge). See “GLOSSARY OF TERMS” for more information regarding the calculation of Cash Value;

●

the Fixed Account portion of the minimum required Cash Value plus the Separate Account portion of the Policy Value, on the date we receive the required information in good order at our Administrative Office; and

●

the guaranteed minimum death benefit (if one was elected) on the date of death; plus premium payments, minus gross withdrawals, from the date of death to the date the death benefit is paid. Please see Appendix - Adjusted Withdrawals - Guaranteed Minimum Death Benefit Riders for illustrative examples regarding death benefit calculations.

Please note: The death benefit terminates upon Annuitization.

Guaranteed Minimum Death Benefit

The guaranteed minimum death benefit terminates upon Annuitization and there is a mandatory Annuity Commencement Date. On the Policy application, You may choose the Annual Step-Up death benefit or the Return of Premium (age limitations may apply) for an additional fee. After the Policy is issued, You cannot make an election and the death benefit cannot be changed.

Annual Step-Up Death Benefit

Under this option, on each Policy anniversary prior to Your 81st birthday, a new “stepped-up” death benefit is determined and becomes the guaranteed minimum death benefit for that Policy Year. This “step-up” death benefit is equal to:

●

the largest Policy Value on the Policy Date or on any Policy anniversary prior to the earlier of the Annuitant's date of death or the Annuitant's 81st birthday; plus

●

any premium payments since the date of any Policy anniversary with the largest Policy Value; minus

●

any adjusted withdrawals (please see Appendix - Adjusted Withdrawals - Guaranteed Minimum Death Benefit Riders) since the date of the Policy anniversary with the largest Policy Value to the date of death; minus

●

withdrawals from the date of death to the date the death benefit is paid.

The Annual Step-Up Death Benefit is not available if You or the Annuitant is 76 or older on the Policy Date. There is an extra charge for this death benefit. See ANNUITY POLICY FEE TABLE AND EXPENSE EXAMPLES.

Designated Investment Options. If You elected the Annual Step-Up Death Benefit, You must allocate 100% of Your Policy Value to one or more of the designated Investment Options approved for the Annual Step-Up Death Benefit. See Appendix - Designated Investment Options for a complete listing of available Investment Options. Requiring that You designate 100% of Your Policy Value to the designated Investment Options, some of which employ strategies that are intended to reduce the risk of loss and/or manage volatility, may reduce investment returns and may reduce the likelihood that we will be required to use our own assets to pay amounts due under this benefit.

Please note:

●

You may transfer amounts among the designated Investment Options; however, You cannot transfer any amount to any other Subaccount if You elect this death benefit.

●

We have processes and procedures in place that will prevent allocation to a Subaccount that is not a designated Investment Option. These processes and procedures include restricting transfers requested by telephone and internet.

●

You will not receive an optional guaranteed minimum death benefit if You do not choose one when You purchase Your Policy.

Return of Premium Death Benefit

The Return of Premium Death Benefit is equal to:

●

total premium payments; minus

●

any adjusted withdrawals (please see Appendix - Adjusted Withdrawals - Guaranteed Minimum Death Benefit Riders) as of the date of death; minus

●

withdrawals from the date of death to the date the death benefit is paid.

This benefit is not available if You or the Annuitant is 86 or older on the Policy Date. There is an extra charge for this death benefit. See ANNUITY POLICY FEE TABLE AND EXPENSE EXAMPLES.

Designated Investment Options. If You elected the Return of Premium Death Benefit, You must allocate 100% of Your Policy Value to one or more of the designated Investment Options approved for the Return of Premium Death Benefit. See Appendix - Designated Investment Options for a complete listing of available designated options. Requiring that You designate 100% of Your Policy Value to the designated Investment Options, some of which employ strategies that are intended to reduce the risk of loss and/or manage volatility, may reduce investment returns and may reduce the likelihood that we will be required to use our own assets to pay amounts due under this benefit.

Please note:

●

You may transfer amounts among the designated Investment Options; however, You cannot transfer any amount to any other Subaccount if You elect this death benefit.

●

You will not receive an optional guaranteed minimum death benefit if You do not choose one when You purchase Your Policy.

The Guaranteed Minimum Death Benefit may vary for certain policies and may not be available for all policies, in all states, at all times or through all financial intermediaries. Once You elect a death benefit and Your Policy is issued, Your death benefit cannot be changed and You will not be impacted by a decision to discontinue offering any particular guaranteed minimum death benefit to new sales.

Adjusted Withdrawal

When You request a withdrawal, Your guaranteed minimum death benefit will be reduced by an amount called the adjusted withdrawal. Under certain circumstances, the adjusted withdrawal may be more than the dollar amount of Your withdrawal request. This will generally be the case if the guaranteed minimum death benefit exceeds the Policy Value at the time of the withdrawal. It is also possible that if a death benefit is paid after You have made a withdrawal, then the total amount paid could be less than the total premium payments. The method of reduction depends on the death benefit in effect.

IF You have elected the Return of Premium death benefit and either the Retirement Income Max® 2.0 rider or Retirement Income Choice® 2.0 rider is in effect on the date the withdrawal is made, THEN gross withdrawals up to the rider withdrawal amount, as defined under the applicable rider, will reduce the Return of Premium death benefit amount on a dollar-for-dollar basis. The portion of a gross withdrawal in excess of the rider withdrawal amount in a rider year will further reduce the Return of Premium death benefit by the greater of the dollar amount of the excess withdrawal or a pro rata amount (in proportion to the reduction in Policy Value), and possibly to zero. The formula for calculating the pro rata amount is (the gross amount of the excess withdrawal * value of the current Death Proceeds immediately after the non-excess portion of the gross withdrawal but immediately prior to the excess portion of the gross withdrawal)/ Policy Value immediately after the non-excess portion of the gross withdrawal but immediately prior to the excess portion of the gross withdrawal.

IF the conditions specified above are not in effect on the date the withdrawal is made, THEN the withdrawal will reduce the applicable guaranteed minimum death benefit by the greater of the dollar amount of the gross withdrawal or a pro rata amount (in proportion to the reduction in Policy Value), and possibly to zero. The formula for calculating the pro rata amount is (the gross amount of the withdrawal * value of the current Death Proceeds immediately prior to the gross withdrawal)/ Policy Value immediately prior to the gross withdrawal.

We have included a detailed explanation of this adjustment with examples in the Appendix - Adjusted Withdrawals - Guaranteed Minimum Death Benefit Riders. If You have a qualified Policy, minimum required distributions rules may require You to request a withdrawal.

Optional Benefit Riders

You may have elected one of the following optional riders previously available for purchase which are no longer available. The following rider grid describes the material features of each of those riders. Please refer to Your personal rider pages and any supplemental mailings for Your specific coverage and features regarding these riders.

Listed below are the abbreviations that will be used in the following grid for Your reference.

Abbreviation	Definition
ADB	Additional Death Benefit
ADD	Additional Death Distribution
ADD+	Additional Death Distribution Plus
DB	Death Benefit
DCA	Dollar Cost Averaging
GFV	Guaranteed Future Value
GMDB	Guaranteed Minimum Death Benefit
GMIB	Guaranteed Minimum Income Benefit
GMLB	Guaranteed Minimum Living Benefit
IE	Income EnhancementSM

Abbreviation	Definition
MRWA	Minimum Remaining Withdrawal Amount
N/A	Not Applicable
RDB	Rider Death Benefit
RIC	Retirement Income Choice®
RMD	Required Minimum Distribution
RWA	Rider Withdrawal Amount
SPO	Systematic Pay Out
TWB	Total Withdrawal Base
WB	Withdrawal Base
WD	Withdrawal

Rider Name	Additional Death Distribution32003	Additional Death Distribution+3	Retirement Income Max®3	Retirement Income Choice® 1.63
Rider Form Number1	RTP 18 0103 ICC12 RTP 170513	RTP 17 0103 ICC12 RTP 180513	RGMB 41 0513 RGMB 41 0111 (NY)	RGMB 37 0809 - (w/o IE) RGMB 38 0809 - (with IE)
Purpose of Rider	This is an Additional Death Benefit Rider which can pay an additional benefit at time of death to help alleviate the burden of taxes.	This is an Additional Death Benefit Rider which can pay an additional benefit at time of death to help alleviate the burden of taxes.	This is a GLWB rider that guarantees withdrawals for the Annuitant's2 lifetime, regardless of Policy Value. ●The policyholder can withdraw the RWA each rider year until the death of the Annuitant.2	This is a GLWB rider that guarantees withdrawals for the Annuitant's2 lifetime, regardless of Policy Value. ●The policyholder can withdraw the RWA each rider year until the death of the Annuitant.2

Rider Name	Additional Death Distribution32003	Additional Death Distribution+3	Retirement Income Max®3	Retirement Income Choice® 1.63
Rider Form Number1	RTP 18 0103 ICC12 RTP 170513	RTP 17 0103 ICC12 RTP 180513	RGMB 41 0513 RGMB 41 0111 (NY)	RGMB 37 0809 - (w/o IE) RGMB 38 0809 - (with IE)
			●This benefit is intended to provide a level of payments regardless of the performance of the designated variable Investment Options You select.	●This benefit is intended to provide a level of payments regardless of the performance of the designated variable Investment Options You select.
Availability	●Issue age 0-75 but not yet 76 years old (Policy application signed on or after May 1, 2020). ●Issue age 0-80 but not yet 81 years old (policy application signed prior to May 1, 2020). ●Not available in all states.	●Issue age 0-75 but not yet 76 years old. ●Not available in all states.	●Issue age 0-85, but not yet 86 years old (unless state law requires a lower maximum issue age). ●Single Annuitant ONLY. Annuitant must be an Owner (unless Owner is a non-natural person) ●Maximum of 2 living Joint Owners (with one being the Annuitant) ●Cannot be added to a Policy with other active GMLB riders.	●Issue age 0-85, but not yet 86 years old (unless state law requires a lower maximum issue age). ●Single Annuitant ONLY. Annuitant must be an Owner (unless Owner is a non-natural person) ●Maximum of 2 living Joint Owners (with one being the Annuitant) ●Cannot be added to a Policy with other active GMLB riders. ●Not available on qualified annuity which has been continued by surviving spouse or beneficiary as a new Owner.
Base Benefit and Optional Fees at issue	Percentage of Policy Value – 0.25%	Percentage of Policy Value – 0.55%	Percentage of withdrawal base - 1.25% For riders issued prior to the date of this prospectus, please reference the “Appendix – Prior Withdrawal/Growth Percentages and Rider Fees” in the Statement of Additional Information.	Fee based on designated allocation groups and the optional benefits selected. If You elect a combination of designated allocations from among the various groups below, then Your fee will be based on a weighted average of Your choices.Rider Fees: Group A1.45% Group B1.10% Group C0.70% Single Life IE0.30% Joint Life IE0.50% For riders issued prior to the date of this prospectus, please reference the “Appendix – Prior Withdrawal/Growth Percentages and Rider Fees” in the Statement of Additional Information.
Fee Frequency	Assessed each rider anniversary and at rider termination and equal to the Policy Value multiplied by rider fee percentage.	Assessed each rider anniversary and at rider termination and equal to the Policy Value multiplied by rider fee percentage.	●The fee is calculated at issue and each subsequent rider quarter for the upcoming quarter based on the fund values and WB at that point in time and stored. ●Deducted at each rider quarterversary in arrears during the accumulation phase. ●The fee is calculated on a quarterly basis.	●The fee is calculated at issue and each subsequent rider quarter for the upcoming quarter based on the fund values and WB at that point in time and stored. ●Deducted at each rider quarterversary in arrears during the accumulation phase. ●The fee is calculated on a quarterly basis and varies

Rider Name	Additional Death Distribution32003	Additional Death Distribution+3	Retirement Income Max®3	Retirement Income Choice® 1.63
Rider Form Number1	RTP 18 0103 ICC12 RTP 170513	RTP 17 0103 ICC12 RTP 180513	RGMB 41 0513 RGMB 41 0111 (NY)	RGMB 37 0809 - (w/o IE) RGMB 38 0809 - (with IE)
			●A rider fee adjustment will be applied for subsequent premium payments and withdrawals that change the withdrawal base. ●The base rider fee adjustment will be calculated using the same formula as the base rider fee. ●The rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be allocated. ●A pro-rated fee is deducted at the time the rider is terminated or upgraded.	depending on the fund allocation option You have chosen. ●A rider fee adjustment will be applied for transfers between allocation groups and for subsequent premium payments and withdrawals that change the withdrawal base. ●The base rider fee adjustment will be calculated using the same formula as the base rider fee. ●The rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be allocated. ●A pro-rated fee is deducted at the time the rider is terminated or upgraded.
Death Benefit	Amount is paid whenever a death benefit is paid and the rider is attached. ●Amount paid=ADB Factor x Rider Earnings* ●ADB Factor - 40% for issue ages 0-70 and 25% for issue ages 71-80 (when application signed date is prior to May 1, 2020). ●ADB Factor - 40% for issue ages 0-70 and 25% for issue ages 71-75 (when application signed date is after May 1, 2020). *Rider earnings are defined as: - the Policy Value on the date the death benefit is determined; minus -Policy Value on the rider date; minus - premium payments after the rider date; plus - surrenders after the rider date that exceed the rider earnings on the date of the surrender. NOTE: No benefit is payable under the ADD rider if there are no rider earnings on the date the death benefit is calculated.	Amount is paid whenever a death benefit is paid and the rider is attached. ●Prior to 5th rider anniversary = Sum of all fees paid for this rider since the rider date. ●On or after 5th rider anniversary = Rider Benefit Base* x Rider Benefit Percentage*. The rider benefit percentage = 30% for issue ages 0-70 and 20% for issue ages 71-75. The Rider Benefit Base at any time is equal to the Policy Value less any premiums added after the Rider Date NOTE: No benefit is payable under the ADD+ rider if the Policy Value on the date the death benefit is paid is less than the premium payments after the rider date.	N/A	N/A
Designated Investment Options Available - Policyholders who add these riders may only invest in the Investment Options listed. Investment Options may not be available as a designated Investment Option based on rider issue date.	N/A	N/A	For a list of designated funds for this rider, please reference the Appendix - Designated Investment Options	For a list of designated funds for this rider, please reference the Appendix - Designated Investment Options

Rider Name	Additional Death Distribution32003	Additional Death Distribution+3	Retirement Income Max®3	Retirement Income Choice® 1.63
Rider Form Number1	RTP 18 0103 ICC12 RTP 170513	RTP 17 0103 ICC12 RTP 180513	RGMB 41 0513 RGMB 41 0111 (NY)	RGMB 37 0809 - (w/o IE) RGMB 38 0809 - (with IE)
Requiring that You designate 100% of Your Policy Value to the designated Investment Options, some of which employ strategies that are intended to reduce the risk of loss and/or manage volatility, may reduce investment returns and may reduce the likelihood that we will be required to use our own assets to pay amounts due under this benefit. PLEASE NOTE: These Investment Options may not be available on all products, may vary for certain policies and may not be available for all policies. Please reference Appendix - Portfolio Companies Available Under the Policy Appendix in Your prospectus for available Portfolio Companies. You cannot transfer any amount to any other non-designated Subaccount without losing all Your benefits under this rider.
Withdrawal Benefits - See Hypothetical Adjusted Withdrawals - Guaranteed Lifetime Withdrawal Benefit Riders for examples showing the effect of withdrawals on the WB.	N/A	N/A	The percentage is determined by the attained age of the Annuitant2 at the time of the first withdrawal. ●Starting the rider anniversary following the Annuitant's259th birthday, the withdrawal percentage increases above 0% which creates a RWA available under the rider for withdrawal. ●On each rider anniversary, the RWA will be reset equal to the greater of: 1)The WB multiplied by the Withdrawal Percentage based on the attained age of the Annuitant2 at the time of their first withdrawal if applicable, and 2)The RMD amount for this Policy for the current calendar year. ●The policyholder does not have to take the entire RWA in any year. ●If they do not take the full amount available, the remaining portion does not carry over to the next rider year. For riders issued prior to the date of this prospectus, please reference the “Appendix – Prior Withdrawal/Growth	The percentage is determined by the attained age of the Annuitant2 at the time of the first withdrawal. ●Starting the rider anniversary following the Annuitant's259th birthday, the withdrawal percentage increases above 0% which creates a RWA available under the rider for withdrawal. ●On each rider anniversary, the RWA will be reset equal to the greater of: 1)The WB multiplied by the Withdrawal Percentage based on the attained age of the Annuitant2 at the time of their first withdrawal if applicable, and 2)The RMD amount for this Policy for the current calendar year. ●The policyholder does not have to take the entire RWA in any year. ●If they do not take the full amount available, the remaining portion does not carry over to the next rider year. For riders issued prior to the date of this prospectus, please reference the “Appendix – Prior Withdrawal/Growth

Rider Name	Additional Death Distribution32003	Additional Death Distribution+3	Retirement Income Max®3	Retirement Income Choice® 1.63
Rider Form Number1	RTP 18 0103 ICC12 RTP 170513	RTP 17 0103 ICC12 RTP 180513	RGMB 41 0513 RGMB 41 0111 (NY)	RGMB 37 0809 - (w/o IE) RGMB 38 0809 - (with IE)
			Percentages and Rider Fees” in the Statement of Additional Information.	Percentages and Rider Fees” in the Statement of Additional Information.
Automatic Step-Up Benefit	N/A	N/A	On each rider anniversary, the WB will be set to the greatest of: 1)The current WB: 2)The Policy Value on the rider anniversary; 3)The highest Policy Value on a rider monthiversarySM; or 4)The current WB immediately prior to anniversary processing increased by the growth rate percentage* * Item 3) is set to zero if there have been any excess withdrawals in the current rider year. ** Item 4) is set to zero after the first 10 years or if there have been any withdrawals in the current rider year. A step-up will occur if the largest value is either 2) or 3) above. A step-up will allow us to change the rider fee percentage after the 1st rider anniversary. ●If the largest value is 1) or 4) above, this is not considered a step-up. ●Owner will have a 30 day window after the rider anniversary to reject an automatic step-up if we increase the rider fee.—Must be in writing. ●If an Owner rejects an automatic step-up, they retain the right to all future automatic step-ups. NOTE: The withdrawal percentage will also increase if You have crossed into another age band prior to an automatic step-up after the election date.	On each rider anniversary, the WB will be set to the greatest of: 1)The current WB: 2)The Policy Value on the rider anniversary; 3)The highest Policy Value on a rider monthiversarySM; or 4)The current WB immediately prior to anniversary processing increased by the growth rate percentage* * Item 3) is set to zero if there have been any excess withdrawals in the current rider year. ** Item 4) is set to zero after the first 10 years or if there have been any withdrawals in the current rider year. A step-up will occur if the largest value is either 2) or 3) above. A step-up will allow us to change the rider fee percentage after the 5th rider anniversary. ●If the largest value is 1) or 4) above, this is not considered a step-up. ●Owner will have a 30 day window after the rider anniversary to reject an automatic step-up if we increase the rider fee.—Must be in writing. ●If an Owner rejects an automatic step-up, they retain the right to all future automatic step-ups. NOTE: The withdrawal percentage will also increase if You have crossed into another age band prior to an automatic step-up after the election date.
Exercising Rider	No further action required to exercise the rider.	No further action required to exercise the rider.	Exercising Base Benefit: The policyholder is guaranteed to be able to withdraw up to the RWA each rider year even if the Policy Value does not reach zero as a result of an excess withdrawal. The rider benefits cease when the Annuitant2 has died.	Exercising Base Benefit: The policyholder is guaranteed to be able to withdraw up to the RWA each rider year even if the Policy Value does not reach zero as a result of an excess withdrawal. The rider benefits cease when the Annuitant2 has died. Exercising the Income Enhancement Option: If qualifications are met, this optional feature doubles the income benefit percentage until the Annuitant2 is no longer confined (either has left

Rider Name	Additional Death Distribution32003	Additional Death Distribution+3	Retirement Income Max®3	Retirement Income Choice® 1.63
Rider Form Number1	RTP 18 0103 ICC12 RTP 170513	RTP 17 0103 ICC12 RTP 180513	RGMB 41 0513 RGMB 41 0111 (NY)	RGMB 37 0809 - (w/o IE) RGMB 38 0809 - (with IE)
				the facility or deceased). Qualifications: –Confinement must be due to a medical necessity due to physical or cognitive ailment. –Must be the Annuitant2 who is confined. –Waiting period of 1 year from the rider date before the increase in the income benefit percentage is applicable. –Elimination period is 180 days within the last 12 months which can be satisfied during the waiting period. –Proof of confinement is required. This may be a statement from a Physician or a hospital or nursing facility administrator. –Qualification standards can be met again on the Annuitant's2 life.
Income Benefit or Other Benefit Payout Considerations	N/A	N/A	Growth: Benefit is not elected separately but is built into the rider. The WB will grow annually. This will only be credited on the rider anniversary for up to 10 rider years. This is not added on top of a step-up if applicable. If a withdrawal has occurred in the current rider year growth will not be applied. For riders issued prior to the date of this prospectus, please reference the “Appendix – Prior Withdrawal/Growth Percentages and Rider Fees” in the Statement of Additional Information. NOTE: There is not an adjustment or credit for partial years of interest. Growth is not accumulated daily. Only calculated at the end of the year if no withdrawals were taken.	Growth: Benefit is not elected separately but is built into the rider. The WB will grow annually. This will only be credited on the rider anniversary for up to 10 rider years. This is not added on top of a step-up if applicable. If a withdrawal has occurred in the current rider year growth will not be applied. For riders issued prior to the date of this prospectus, please reference the “Appendix – Prior Withdrawal/Growth Percentages and Rider Fees” in the Statement of Additional Information. NOTE: There is not an adjustment or credit for partial years of interest. Growth is not accumulated daily. Only calculated at the end of the year if no withdrawals were taken.
Rider Upgrade	N/A	N/A	N/A	●Upgrades allowed within a 30-day window following each successive 5th rider anniversary. ●Rider availability and fees may vary at time of upgrade ●Upgrades are subject to issue age restrictions of the rider at the time of upgrade. Currently the maximum upgrade age is 85 years old. ●An upgrade will reset the WB and RDB.

Rider Name	Additional Death Distribution32003	Additional Death Distribution+3	Retirement Income Max®3	Retirement Income Choice® 1.63
Rider Form Number1	RTP 18 0103 ICC12 RTP 170513	RTP 17 0103 ICC12 RTP 180513	RGMB 41 0513 RGMB 41 0111 (NY)	RGMB 37 0809 - (w/o IE) RGMB 38 0809 - (with IE)
				●Rider Fee Percentage will be the fee percentage that applies to the new rider at the time of upgrade. ●Growth percentage will be the percentage available at the time of upgrade.
Rider Termination	The rider can be added or dropped at any time. If the rider is dropped and re-added, the rider will only cover earnings accumulated since the rider was re-added. The rider will remain in effect until: ●You cancel it by notifying our Administrative Office in writing, ●the Policy is Annuitized or surrendered, ●or the additional death benefit is paid.	The rider can be added or dropped at any time. If the rider is terminated they must wait one year to re-add rider. The rider will remain in effect until: ●You cancel it by notifying our Administrative Office in writing, ●the Policy is Annuitized or surrendered, ●or the additional death benefit is paid.	●The rider will be terminated upon Policy surrender, Annuitization, Annuitant2 death or upgrade. ●The date the Policy to which this rider is attached is assigned or if the Owner is changed without our approval. ●Termination allowed within 30 day window following each successive 5th rider anniversary. ●The rider will be terminated the date an excess withdrawal reduces Your Policy Value to zero, or we receive Written Notice from You requesting termination. ●After termination, there is no wait period to re-add the rider, assuming the rider is still being offered.	●The rider will be terminated upon Policy surrender, Annuitization, Annuitant2 death or upgrade. ●The date the Policy to which this rider is attached is assigned or if the Owner is changed without our approval. ●Termination allowed within 30 day window following each successive 5th rider anniversary. ●The rider will be terminated the date an excess withdrawal reduces Your Policy Value to zero, or we receive Written Notice from You requesting termination. ●After termination, there is no wait period to re-add the rider, assuming the rider is still being offered.

Rider Name	Retirement Income Max®2.03	Retirement Income Choice®2.03	Transamerica Income EdgeSM3
Rider Form Number1	RGMB 50 0515 Single and Joint Life	RGMB 48 0515 Single and Joint Life	RGMB 51 0616
Purpose of Rider	This is a GLWB rider that guarantees withdrawals for the Annuitant's2 lifetime, regardless of Policy Value. ●The policyholder can withdraw the RWA each rider year until the death of the Annuitant.2 ●This benefit is intended to provide a level of payments regardless of the performance of the designated variable Investment Options You select.	This is a GLWB rider that guarantees withdrawals for the Annuitant's2 lifetime, regardless of Policy Value. ●The policyholder can withdraw the RWA each rider year until the death of the Annuitant.2 ●This benefit is intended to provide a level of payments regardless of the performance of the designated variable Investment Options You select.	This is a GLWB rider that guarantees withdrawals for the Annuitant's2 lifetime, regardless of Policy Value. ●The policyholder can withdraw the RWA each rider year until the death of the Annuitant.2 ●This benefit is intended to provide a level of payments regardless of the performance of the designated Investment Options You select.
Availability	●Issue age 0-85, but not yet 86 years old (unless state law requires a lower maximum issue age). ●Single Annuitant ONLY. Annuitant must be an Owner (unless Owner is a non-natural person) ●Maximum of 2 living Joint Owners (with one being the Annuitant) ●Cannot be added to a Policy with other active GMLB riders.	●Issue age 0-85, but not yet 86 years old (unless state law requires a lower maximum issue age). ●Single Annuitant ONLY. Annuitant must be an Owner (unless Owner is a non-natural person) ●Maximum of 2 living Joint Owners (with one being the Annuitant) ●Cannot be added to a Policy with other active GMLB riders.	●Issue age 0-85, but not yet 86 years old (unless state law requires a lower maximum issue age). ●Single Annuitant ONLY. Annuitant must be an Owner (unless Owner is a non-natural person) ●Maximum of 2 living Joint Owners (with one being the Annuitant) ●Cannot be added to a Policy with other active GMLB riders.

Rider Name	Retirement Income Max®2.03	Retirement Income Choice®2.03	Transamerica Income EdgeSM3
Rider Form Number1	RGMB 50 0515 Single and Joint Life	RGMB 48 0515 Single and Joint Life	RGMB 51 0616
	●Not available on qualified annuity which has been continued by surviving spouse or beneficiary as a new Owner.	●Not available on qualified annuity which has been continued by surviving spouse or beneficiary as a new Owner.	●Not available on qualified annuity which has been continued by surviving spouse or beneficiary as a new Owner.
Base Benefit and Optional Fees at issue	Rider Fees: Single Life1.50% Joint Life1.60% For riders issued prior to the date of this prospectus, please reference the “Appendix – Prior Withdrawal/Growth Percentages and Rider Fees” in the Statement of Additional Information.	Fee based on designated allocation groups and the optional benefits selected. If You elect a combination of designated allocations from among the various groups below, then Your fee will be based on a weighted average of Your choices. Rider Fees: Single Life Group A1.85% Group B1.40% Group C0.95% Joint Life Group A1.95% Group B1.50% Group C1.05% For riders issued prior to the date of this prospectus, please reference the “Appendix – Prior Withdrawal/Growth Percentages and Rider Fees” in the Statement of Additional Information.	We use the withdrawal base to calculate the rider withdrawal amount and the rider fee. The withdrawal base on the rider date is the Policy Value. Rider Fees: Single Life1.45% Joint Life1.55% For riders issued prior to the date of this prospectus, please reference the “Appendix – Prior Allocation/Withdrawal Percentages and Rider Fees” in the Statement of Additional Information.
Fee Frequency	●The fee is calculated at issue and each subsequent rider quarter for the upcoming quarter based on the fund values and WB at that point in time and stored. ●Deducted at each rider quarterversary in arrears during the accumulation phase. ●The fee is calculated on a quarterly basis. ●A rider fee adjustment will be applied for subsequent premium payments and withdrawals that change the withdrawal base. ●The base rider fee adjustment will be calculated using the same formula as the base rider fee. ●The rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be allocated. ●A pro-rated fee is deducted at the time the rider is terminated or upgraded.	●The fee is calculated at issue and each subsequent rider quarter for the upcoming quarter based on the fund values and WB at that point in time and stored. ●Deducted at each rider quarterversary in arrears during the accumulation phase. ●The fee is calculated on a quarterly basis and varies depending on the fund allocation option You have chosen. ●A rider fee adjustment will be applied for transfers between allocation groups and for subsequent premium payments and withdrawals that change the withdrawal base. ●The base rider fee adjustment will be calculated using the same formula as the base rider fee. ●The rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be allocated. ●A pro-rated fee is deducted at the time the rider is terminated or upgraded.	●The fee is calculated at issue and each subsequent rider quarter for the upcoming quarter ●Deducted at each rider quarter and will be deducted automatically from the flexible Investment Options and the select Investment Options on a pro-rata basis at the end of each rider quarter. ●The fee is calculated and stored at issue and at each subsequent rider quarter for the upcoming quarter. ●A rider fee adjustment will be applied for any premium additions and excess withdrawals that change the withdrawal base. ●The rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be collected. ●A pro-rated fee is deducted at the time the rider is terminated.
Death Benefit	N/A	N/A	N/A
Designated Investment Options Available - Policyholders who add these riders may only invest in the Investment Options listed. Investment Options may not be available as a designated fund based on rider issue date.	For a list of designated funds for this rider, please reference the Appendix Designated Investment Options.	For a list of designated funds for this rider, please reference the Appendix Designated Investment Options.	For a list of Select and Flexible Investment Option, please reference the Appendix - Transamerica Income EdgeSM Investment Options.

Rider Name	Retirement Income Max®2.03	Retirement Income Choice®2.03	Transamerica Income EdgeSM3
Rider Form Number1	RGMB 50 0515 Single and Joint Life	RGMB 48 0515 Single and Joint Life	RGMB 51 0616
Requiring that You designate 100% of Your Policy Value to the designated Investment Options, some of which employ strategies that are intended to reduce the risk of loss and/or manage volatility, may reduce investment returns and may reduce the likelihood that we will be required to use our own assets to pay amounts due under this benefit. PLEASE NOTE: These Investment Options may not be available on all products, may vary for certain policies and may not be available for all policies. Please reference Appendix - Portfolio Companies Available Under the Policy in Your prospectus for available funds. You cannot transfer any amount to any other non-designated Subaccount without losing all Your benefits under this rider.
Allocation Methods	N/A	N/A	Required Allocations: A certain percentage of Your Policy Value on the rider date must be allocated to the Stable Account, the select and the flexible Investment Options as specified in the applicable Rate Sheet Prospectus Supplement. Stable Account: ●This is a Fixed Account option. ●Allocations applied to the Stable Account will be credited interest based on a fixed rate. ●Withdrawals from the Stable Account are not permitted until all over Investment Options are depleted of value. Flexible and Select Options: ●You must allocate certain percentages of Your premium payments and Policy Value to these Investment Options. ●If You do not wish to maintain the required allocation percentages the rider must be terminated. ●Withdrawals from the flexible and select Investment Options will be deducted on a pro-rated basis from each Investment Option that You have allocated to. For riders issued prior to the date of this prospectus, please reference the “Appendix – Prior Allocation/Withdrawal Percentages and Rider Fees” in the Statement of Additional Information.
Withdrawal Benefits - See Hypothetical Adjusted Withdrawals - Guaranteed Lifetime Withdrawal Benefit Riders appendix for examples showing the effect of withdrawals on the WB.	The percentage is determined by the attained age of the Annuitant2 at the time of the first withdrawal. For riders issued prior to the date of this prospectus, please reference the “Appendix – Prior Withdrawal/Growth Percentages and	The percentage is determined by the attained age of the Annuitant2 at the time of the first withdrawal. For riders issued prior to the date of this prospectus, please reference the “Appendix – Prior	The withdrawal percentage is determined by the attained age of the Annuitant2 at the time of the first withdrawal. Single Life Riders Age 1st WD during Rider Years

Rider Name	Retirement Income Max®2.03	Retirement Income Choice®2.03	Transamerica Income EdgeSM3
Rider Form Number1	RGMB 50 0515 Single and Joint Life	RGMB 48 0515 Single and Joint Life	RGMB 51 0616
	Rider Fees” in the Statement of Additional Information. ●Starting the rider anniversary following the Annuitant's259th birthday, the withdrawal percentage increases above 0% which creates a RWA available under the rider for withdrawal. ●On each rider anniversary, the RWA will be reset equal to the greater of: 1)The WB multiplied by the withdrawal percentage based on the attained age of the Annuitant2 at the time of their first withdrawal if applicable, and 2)The RMD amount for this Policy for the current calendar year. ●The policyholder does not have to take the entire RWA in any year. ●If they do not take the full amount available, the remaining portion does not carry over to the next rider year.	Withdrawal/Growth Percentages and Rider Fees” in the Statement of Additional Information. ●Starting the rider anniversary following the Annuitant's259th birthday, the withdrawal percentage increases above 0% which creates a RWA available under the rider for withdrawal. ●On each rider anniversary, the RWA will be reset equal to the greater of: 1)The WB multiplied by the withdrawal percentage based on the attained age of the Annuitant2 at the time of their first withdrawal if applicable, and 2)The RMD amount for this Policy for the current calendar year. ●The policyholder does not have to take the entire RWA in any year. ●If they do not take the full amount available, the remaining portion does not carry over to the next rider year.	1-5Single Life WD% 0 - 580.00% 59-643.75% 65-805.00% 81 +5.50% Joint Life Riders Age 1st WD during Rider Years 1-5Joint Life WD% 0 - 580.00% 59-643.25% 65-804.50% 81 +5.00% Single Life Riders Age 1st WD during Rider Years 6-10Single Life WD% 0 - 580.00% 59-644.25% 65-805.50% 81 +6.00% Joint Life Riders Age 1st WD during Rider Years 6-10Joint Life WD% 0 - 580.00% 59-643.75% 65-805.00% 81 +5.50% Single Life Riders Age 1st WD during Rider Years 11+Single Life WD% 0 - 580.00% 59-644.75% 65-806.00% 81 +6.50% Joint Life Riders Age 1st WD during Rider Years 11+Joint Life WD% 0 - 580.00% 59-644.25% 65-805.50% 81 +6.00% For riders issued prior to the date of this prospectus, please reference the “Appendix – Prior Allocation/Withdrawal Percentages and Rider Fees” in the Statement of Additional Information.
Automatic Step-Up Benefit	On each rider anniversary, the WB will be set to the greatest of: 1)The current WB: 2)The Policy Value on the rider anniversary; 3)The highest Policy Value on a rider monthiversarySM; or 4)The current WB immediately prior to anniversary processing increased by the growth rate percentage* * Item 3) is set to zero if there have been any excess withdrawals in the current rider year. ** Item 4) is set to zero after the first 10 years or if there have been any withdrawals in the current rider year. A step-up will occur if the largest value is either 2) or 3) above. A step-up will allow us to change the rider fee percentage after the 1st rider anniversary.	On each rider anniversary, the WB will be set to the greatest of: 1)The current WB: 2)The Policy Value on the rider anniversary; 3)The highest Policy Value on a rider monthiversarySM; or 4)The current WB immediately prior to anniversary processing increased by the growth rate percentage* * Item 3) is set to zero if there have been any excess withdrawals in the current rider year. ** Item 4) is set to zero after the first 10 years or if there have been any withdrawals in the current rider year. A step-up will occur if the largest value is either 2) or 3) above. A step-up will allow us to change the rider fee percentage after the 5th rider anniversary.	On each rider anniversary, the rider will receive an automatic step-up if the WB is equal to the Policy Value on the rider anniversary immediately after the WB reset on the rider anniversary. ●If the Policy Value is not greater than the current WB no automatic step-up will occur ●The withdrawal percentage will also increase if You have crossed into another age band or rider year duration prior to the step-up. ●The rider fee percentage may increase or decrease at the time of the step-up. ●Owner will have a 30 day window after the rider anniversary to reject an automatic step-up if the rider fee increased.

Rider Name	Retirement Income Max®2.03	Retirement Income Choice®2.03	Transamerica Income EdgeSM3
Rider Form Number1	RGMB 50 0515 Single and Joint Life	RGMB 48 0515 Single and Joint Life	RGMB 51 0616
	●If the largest value is 1) or 4) above, this is not considered a step-up. ●Owner will have a 30 day window after the rider anniversary to reject an automatic step-up if we increase the rider fee.—Must be in writing. ●If an Owner rejects an automatic step-up, they retain the right to all future automatic step-ups. NOTE: The benefit percentage will also increase if You have crossed into another age band prior to an automatic step-up after the election date.	●If the largest value is 1) or 4) above, this is not considered a step-up. ●Owner will have a 30 day window after the rider anniversary to reject an automatic step-up if we increase the rider fee.—Must be in writing. ●If an Owner rejects an automatic step-up, they retain the right to all future automatic step-ups. NOTE: The benefit percentage will also increase if You have crossed into another age band prior to an automatic step-up after the election date.	●If an Owner rejects an automatic step-up, they retain the right to all future automatic step-ups.
Exercising Rider	Exercising Base Benefit: The policyholder is guaranteed to be able to withdraw up to the RWA each rider year if the Policy Value does not reach zero as a result of an excess withdrawal. The rider benefits cease when the Annuitant2 has died.	Exercising Base Benefit: The policyholder is guaranteed to be able to withdraw up to the RWA each rider year if the Policy Value does not reach zero as a result of an excess withdrawal. The rider benefits cease when the Annuitant2 has died.	Exercising Base Benefit: The policyholder is guaranteed to be able to withdraw up to the RWA each rider year (after the attainment of the minimum benefit age) without causing an excess withdrawal, even if the Policy Value is zero at the time of withdrawal. The rider benefits cease when the Annuitant2 has died.
Income Benefit or Other Benefit Payout Considerations	Growth: Benefit is not elected separately but is built into the rider. The WB will grow annually. This will only be credited on the rider anniversary for up to 10 rider years. This is not added on top of a step-up if applicable. If a withdrawal has occurred in the current rider year growth will not be applied. For riders issued prior to the date of this prospectus, please reference the “Appendix – Prior Withdrawal/Growth Percentages and Rider Fees” in the Statement of Additional Information. NOTE: There is not an adjustment or credit for partial years of interest. Growth is not accumulated daily. Only calculated at the end of the year if no withdrawals were taken.	Growth: Benefit is not elected separately but is built into the rider. The WB will grow annually. This will only be credited on the rider anniversary for up to 10 rider years. This is not added on top of a step-up if applicable. If a withdrawal has occurred in the current rider year growth will not be applied. For riders issued prior to the date of this prospectus, please reference the “Appendix – Prior Withdrawal/Growth Percentages and Rider Fees” in the Statement of Additional Information. NOTE: There is not an adjustment or credit for partial years of interest. Growth is not accumulated daily. Only calculated at the end of the year if no withdrawals were taken.	N/A
Rider Upgrade	N/A	This rider is no longer sold, upgrades are no longer available.	This rider is no longer sold, upgrades are no longer available.
Rider Termination	●The rider will be terminated upon Policy surrender, Annuitization, Annuitant2 death or upgrade. ●The date the Policy to which this rider is attached is assigned or if the Owner is changed without our approval. ●Termination allowed within 30 day window following each successive 5th rider anniversary. ●The rider will be terminated the date an excess withdrawal reduces Your	●The rider will be terminated upon Policy surrender, Annuitization, Annuitant2 death or upgrade. ●The date the Policy to which this rider is attached is assigned or if the Owner is changed without our approval. ●Termination allowed within 30 day window following each successive 5th rider anniversary. ●The rider will be terminated the date an excess withdrawal reduces Your	●The rider will be terminated upon Policy surrender, Annuitization, Annuitant2 death or upgrade. ●The date the Policy to which this rider is attached is assigned or if the Owner is changed without our approval. ●Termination allowed within 30 day window following each successive 5th rider anniversary. ●The rider will be terminated the date an excess withdrawal reduces Your

Rider Name	Retirement Income Max®2.03	Retirement Income Choice®2.03	Transamerica Income EdgeSM3
Rider Form Number1	RGMB 50 0515 Single and Joint Life	RGMB 48 0515 Single and Joint Life	RGMB 51 0616
	Policy Value to zero, or we receive Written Notice from You requesting termination.	Policy Value to zero, or we receive Written Notice from You requesting termination.	Policy Value to zero, or we receive Written Notice from You requesting termination.

(1)

Rider form number may be found on the bottom left corner of your rider pages.

(2)

If the rider's Joint Life option has been elected for an additional fee, the benefits and features available could differ from the Single Life Option based on the age of the Annuitant's spouse if younger.

(3)

This rider and additional options may vary for certain policies and may not be available for all policies. This disclosure explains the material features of the riders. The application and operation of the riders are governed by the terms and conditions of the rider itself.

ADDITIONAL FEATURES

Systematic Payout Option

You can select at any time during the accumulation phase to receive regular withdrawals from Your Policy by using the systematic payout option. Any systematic withdrawal in excess of the cumulative interest credited from the Guaranteed Period Options at the time of the withdrawal may be subject to an Excess Interest Adjustment. Any systematic withdrawal in excess of Your remaining Surrender Charge Free Amount may be subject to a surrender charge. Any systematic withdrawal could reduce Your rider values (perhaps significantly). Systematic withdrawals can be taken monthly, quarterly, semi-annually, or annually. Each withdrawal must be at least $40. Monthly and quarterly systematic withdrawals must generally be taken by electronic funds transfer directly to Your checking or savings account. There is no charge for this benefit.

Keep in mind that withdrawals under the systematic payout option may be taxable, and if taken before age 59½, may be subject to a 10% federal penalty tax.

Nursing Care and Terminal Condition Waiver

No surrender charges or Excess Interest Adjustments will apply if You take a withdrawal ($1,000 minimum), under certain circumstances, because You or Your spouse has been:

●

confined in a hospital or nursing facility for 30 days in a row after the Policy issue date; or

●

diagnosed with a terminal condition after the Policy issue date (usually a life expectancy of 12 months or less).

You must provide written proof from Your Physician, hospital or nursing facility, which verifies that You qualify for this waiver.

You may exercise this benefit at any time during the accumulation phase. This benefit is also available to the Annuitant or Annuitant's spouse if the Owner is not a natural person. There is no restriction on the maximum amount You may withdraw under this benefit. There is no charge for this benefit.

The Nursing Care and Terminal Condition Waiver may vary for certain policies and may not be available for all policies, in all states or at all times.

Unemployment Waiver

No surrender charges or Excess Interest Adjustments will apply to withdrawals after You or Your spouse become unemployed due to:

●

involuntary termination of employment

●

involuntary lay off;

In order to qualify, You (or Your spouse, whichever is applicable) must have been:

●

employed full time for at least two years prior to becoming unemployed;

●

employed full time on the Policy Date;

●

unemployed for at least 60 days in a row at the time of withdrawal;

●

must have a minimum Cash Value at the time of withdrawal of $5,000; and

●

You (or Your spouse) must be receiving unemployment benefits.

You must provide written proof from Your State's Department of Labor, which verifies that You qualify for and are receiving unemployment benefits at the time of withdrawal.

You may use this benefit at any time during the accumulation phase and for so long as You meet the criteria specified above. This benefit is also available to the Annuitant or Annuitant's spouse if the Owner is not a natural person. There is no restriction on the maximum amount You may withdraw under this benefit. There is no charge for this benefit.

The Unemployment Waiver may vary for certain policies and may not be available for all policies, in all states or at all times.

Telephone and Electronic Transactions

Currently, certain transactions may be made by telephone or other electronic means acceptable to us upon our receipt of the appropriate authorization. We may discontinue this option at any time. To access information and perform transactions electronically, we require You to create an account with a username and password, and to maintain a valid e-mail address.

We will not be liable for following instructions communicated by telephone or electronically we reasonably believe to be genuine. We will employ reasonable procedures to confirm that instructions we receive are genuine. Our procedures require You to provide information to verify Your identity when You call us and we will record conversations with You. We may also require written confirmation of the request. When someone contacts our Administrative Office and follows our procedures, we will assume You are authorizing us to act upon those instructions. For electronic transactions through the internet, You will need to provide Your username and password. You are responsible for keeping Your password confidential and must notify us of any loss, theft or unauthorized use of Your password.

Telephone and other electronic transactions must be received in good order while the New York Stock Exchange is open for regular trading to get same-day pricing of the transaction. Transactions received in good order on non-Business Days or after our close of business on Business Days will get next-day pricing. See OTHER INFORMATION – Sending Forms and Transaction Requests in Good Order. Please note that the telephone and/or electronic device transactions may not always be available. Any telephone, fax machine or other electronic device, whether it is Yours, Your service provider's, or Your financial representative(s) can experience outages or slowdowns for a variety of reasons. These outages or slowdowns may delay or prevent our processing of Your request if the volume of transactions is unusually high, we might not have anyone available, or lines available, to take Your transaction. Although we have taken precautions to limit these problems, we cannot promise complete reliability under all circumstances. If You are experiencing problems, You should make Your request by writing to our Administrative Office.

We reserve the right to revoke Your telephone and other electronic transaction privileges at any time without revoking all Owners' privileges. We may deny telephone and electronic transaction privileges to market timers or disruptive traders.

Dollar Cost Averaging Program

During the accumulation phase, You may instruct us to automatically make transfers into one or more Subaccounts in accordance with Your allocation instructions. This is known as Dollar Cost Averaging. While Dollar Cost Averaging buys more Accumulation Units when prices are low and fewer Accumulation Units when prices are high, it does not guarantee profits or assure that You will not experience a loss.

Dollar Cost Averaging programs that may be available under Your Policy:

●

Traditional – You may specify the dollar amount to be transferred and the number of transfers, or just the number of transfers, in which case we will calculate the amount to be transferred. Unless a specified date is requested, transfers will begin as soon as the program is started. A minimum of $500 per transfer is required. The minimum number of transfers is 6 monthly transfers or 4 quarterly transfers, and the maximum is 24 monthly transfers or 8 quarterly transfers. You can elect to transfer from the Fixed Account, money market or other specified Subaccount. If You elect to transfer from the Fixed Account, or if You elect to transfer from the money market or other specified Subaccount and only the number of transfers is provided, we will transfer 100% of the remaining value in the elected source Subaccount for the final transfer. If the money market or other Subaccount is elected as the source Subaccount and a specified dollar amount is provided with the number of transfers, You must choose if You want to transfer all remaining value out of the source Subaccount or if You would like any remaining value to stay within the Subaccount.

●

Special – You may only elect either a six or twelve month program. Transfers will begin as soon as the program is started. You cannot transfer from another Investment Option into a Special Dollar Cost Averaging program. This program is only available for new premium payments, requires transfers from a fixed source, and may credit a higher or lower interest rate than a traditional program. A minimum of $500 per transfer is required ($3,000 or $6,000 to start a 6-month or 12-month program, respectively). If the value in the source fund is less than the scheduled transfer, 100% of the value remaining in the source fund will be transferred for the final transfer.

Unless a specific date is requested, the Dollar Cost Averaging program will begin the next market day after we have received in good order all necessary information and the minimum required amount. See Sending Forms and Transaction Requests in Good Order. Please Note: Dollar Cost Averaging programs will not begin on the 29th, 30th or 31st. If a program would have started on one of those

dates, it will start on the 1st Business Day of the following month. If we receive additional premium payments while a Dollar Cost Averaging program is running, and You instruct us to add it to the Dollar Cost Averaging program, the amount of the Dollar Cost Averaging transfers will increase proportionally.

NOTE CAREFULLY:

New Dollar Cost averaging instructions are required to start a new Dollar Cost Averaging program once the previous Dollar Cost Averaging program has completed. Additional premium payments, absent new allocation instructions, received after a Dollar Cost Averaging program has completed, will be allocated according to the current premium payment allocations at that time but will not reactivate a completed Dollar Cost Averaging program.

IF:

●

we do not receive all necessary information to begin or restart a Dollar Cost Averaging program

THEN:

●

any amount allocated to a fixed source will be invested in that fixed source but will be transferred to the money market Investment Option within 30 days of allocation to fixed source if new Dollar Cost Averaging instructions are not received;

●

any amount allocated to a variable source will be invested in that variable source and will remain in that variable Investment Option; and

●

new Dollar Cost Averaging instructions will be required to begin a Dollar Cost Averaging program.

You should consider Your ability to continue a Dollar Cost Averaging program during all economic conditions. Transfers from a Dollar Cost Averaging fixed source are not subject to an Excess Interest Adjustment. A Dollar Cost Averaging program can be used in conjunction with Asset Rebalancing and may be available with the Guaranteed Lifetime Withdrawal Benefits. Any amount in the Dollar Cost Averaging source account or any Fixed Account are ignored for the purposes of Asset Rebalancing. There is no charge for this benefit.

The Dollar Cost Averaging Program may vary for certain policies and may not be available for all policies, in all states or at all times. See Your Policy for availability of the Fixed Account options. We reserve the right to terminate the availability of any Dollar Cost Averaging program at any time.

Asset Rebalancing

During the accumulation phase You can instruct us to automatically rebalance the amounts in Your Subaccounts to maintain Your desired asset allocation. This feature is called asset rebalancing and can be started and stopped at any time. If a transfer is requested, we will honor the requested transfer and discontinue asset rebalancing. New instructions are required to start asset rebalancing. Asset rebalancing ignores amounts in the Fixed Account. You can choose to rebalance monthly, quarterly, semi-annually, or annually. Asset rebalancing can be used in conjunction with a Guaranteed Lifetime Withdrawal Benefit. There is no charge for this benefit. We reserve the right to terminate the availability of any asset rebalancing program at any time.

Loans

No Loans are available on this Policy.

TAX INFORMATION

NOTE: We have prepared the following information on federal taxes as a general discussion of the subject. It is not intended as tax advice to any taxpayer. The federal tax consequences discussed herein reflects our understanding of current law, and the law may change. No representation is made regarding the likelihood of continuation of the present federal tax law or of the current interpretations by the Internal Revenue Service. The discussion briefly references federal estate, gift and generation-skipping transfer taxes, but principally discusses federal income taxes. No attempt is made to consider any applicable state or other income tax laws, any state and local estate or inheritance tax, or other tax consequences of ownership or receipt of distributions under the Policy. You should consult Your own financial professional about Your own circumstances.

Introduction

Deferred annuity policies are a way of setting aside money for future needs like retirement. Congress recognized how important saving for retirement is and provided special rules in the Internal Revenue Code (the “Code”) for annuities. Simply stated, these rules generally provide that individuals will not be taxed on the earnings, if any, on the money held in an annuity Policy until withdrawn.

This is referred to as tax deferral. When a non-natural person (e.g., corporation or certain trusts) owns a nonqualified Policy, the Policy will generally not be treated as an annuity for tax purposes. Thus, the Owner must generally include in income any increase in the Policy Value over the investment in the Policy during each taxable year.

There are different rules as to how You will be taxed depending on how You take the money out and the type of Policy-qualified or nonqualified.

If You purchase the Policy as an individual retirement annuity or as a part of a 403(b) plan, 457 plan, a pension plan, a profit sharing plan (including a 401(k) plan), or certain other employer sponsored retirement program, Your Policy is referred to as a qualified Policy. There is no additional tax deferral benefit derived from placing qualified funds into a variable annuity. Features other than tax deferral should be considered in the purchase of a qualified Policy. There are limits on the amount of contributions You can make to a qualified Policy. Other restrictions may apply including terms of the plan in which You participate. To the extent there is a conflict between a plan's provisions and a Policy's provisions, the plan's provisions will control.

If You purchase the Policy other than as part of any arrangement described in the preceding paragraph, the Policy is referred to as a nonqualified Policy.

You will generally not be taxed on increases in the value of Your Policy, whether qualified or nonqualified, until a distribution occurs (e.g., as a surrender, withdrawal, or as annuity payments). However, You may be subject to current taxation if You assign or pledge or enter into an agreement to assign or pledge any portion of the Policy. You may also be subject to current taxation if You make a gift of a nonqualified Policy without valuable consideration. All amounts received from the Policy that are includible in income are taxed at ordinary income rates; no amounts received from the Policy are taxable at the lower rates applicable to capital gains.

The Internal Revenue Service (“IRS”) has not reviewed the Policy for qualification as an IRA annuity, and has not addressed in a ruling of general applicability whether the death benefit options and riders available, with the Policy, if any, comport with IRA qualification requirements.

The value of living and death benefit options and riders elected may need to be taken into account in calculating minimum required distributions from a qualified plan/or Policy.

We may occasionally enter into settlements with Owners and beneficiaries to resolve issues relating to the Policy. Such settlements will be reported on the applicable tax form (e.g., Form 1099) provided to the taxpayer and the taxing authorities.

Taxation of Us

We at present are taxed as a life insurance company under part I of Subchapter L of the Code. The Separate Account is treated as a part of us and, accordingly, will not be taxed separately as a “regulated investment company” under Subchapter M of the Code. We do not expect to incur any federal income tax liability with respect to investment income and net capital gains arising from the activities of the Separate Account retained as part of the reserves under the Policy. Based on this expectation, it is anticipated that no charges will be made against the Separate Account for federal income taxes. If in future years, any federal income taxes are incurred by us with respect to the Separate Account, we may make a charge to that account. We may benefit from any deductions for dividends received by the Separate Account or foreign tax credits attributable to taxes paid by certain underlying fund portfolios to foreign jurisdictions to the extent permitted under federal tax law.

Tax Status of a Nonqualified Policy

Diversification Requirements. In order for a nonqualified variable Policy which is based on a segregated asset account to qualify as an annuity Policy under Section 817(h) of the Code, the investments made by such account must be “adequately diversified” in accordance with Treasury Regulations. The Regulations apply a diversification requirement to each of the Subaccounts. Each Separate Account, through its underlying fund portfolios and their portfolios, intends to comply with the diversification requirements of the Regulations. We have entered into agreements with each underlying fund Portfolio Company that require the portfolios to be operated in compliance with the Regulations but we do not have control over the underlying fund Portfolio Companies. The Owners bear the risk that the entire contract could be disqualified as an annuity Policy under the Code due to the failure of a Subaccount to be deemed to be “adequately diversified.”

Owner Control. In some circumstances, Owners of variable policies who retain excessive control over the investment of the underlying Separate Account assets may be treated as the Owners of those assets and may be subject to tax on income produced by those assets. In Revenue Ruling 2003-91, the IRS stated that whether the Owner of a variable contract is to be treated as the Owner of the assets held by the insurance company under the contract will depend on all of the facts and circumstances.

Revenue Ruling 2003-91 also gave an example of circumstances under which the Owner of a variable contract would not possess sufficient control over the assets underlying the contract to be treated as the Owner of those assets for federal income tax purposes. To the extent the circumstances relating to the issuance and ownership of a Policy vary from those described in Revenue Ruling 2003-91, Owners bear the risk that they will be treated as the Owner of Separate Account assets and taxed accordingly.

We believe that the Owner of a Policy should not be treated as the Owner of the underlying assets. We reserve the right to modify the policies to bring them into conformity with applicable standards should such modification be necessary to prevent Owners of the policies from being treated as the Owners of the underlying Separate Account assets. Concerned Owners should consult their own financial professionals regarding the tax matter discussed above.

Distribution Requirements. The Code requires that nonqualified policies contain specific provisions for distribution of Policy proceeds upon the death of any Owner. In order to be treated as an annuity Policy for federal income tax purposes, the Code requires that such policies provide that if any Owner dies on or after the annuity starting date and before the entire interest in the Policy has been distributed, the remaining portion must be distributed at least as rapidly as under the method in effect on such Owner's death. If any Owner dies before the annuity starting date, the entire interest in the Policy must generally be distributed (1) within 5 years after such Owner's date of death or (2) for the benefit of a designated beneficiary over the life of such designated beneficiary or over a period not extending beyond the life expectancy of such beneficiary and such distribution begin not later than 1 year after the date of the Owner’s death (also known as a “stretch” payout.). The designated beneficiary must be an individual. The only method we use for making distribution payments from a nonqualified “stretch” payment option is the required minimum distribution method as set forth in Revenue Ruling 2022-6. The applicable payments are calculated using the Single Life Expectancy Table set forth in Treasury Regulations 1.401(a)(9)-9(b). However, if upon such Owner's death prior to the Owner's surviving spouse is the sole beneficiary, of the Policy, then the Policy may be continued with the surviving spouse as the new Owner. If any Owner is a non-natural person (except in the case of certain grantor trusts), then for purposes of these distribution requirements, the primary Annuitant shall be treated as an Owner and any death or change of such primary Annuitant shall be treated as the death of an Owner.

The nonqualified policies contain provisions intended to comply with these requirements of the Code. No regulations interpreting these requirements of the Code have yet been issued and thus no assurance can be given that the provisions contained in the policies satisfy all such Code requirements. The provisions contained in the policies will be reviewed and modified if necessary to assure that they comply with the Code requirements when clarified by regulation or otherwise.

Taxation of a Nonqualified Policy

The following discussion assumes the Policy qualifies as an annuity contract for federal income tax purposes.

In General. Code Section 72 governs taxation of annuities in general. We believe that an Owner who is an individual will not be taxed on increases in the value of a Policy until such amounts are surrendered or distributed. For this purpose, the assignment, pledge, or agreement to assign or pledge any portion of the Policy Value as collateral for a loan generally will be treated as a distribution of such portion. You may also be subject to current taxation if You make a gift of a nonqualified Policy without valuable consideration. The taxable portion of a distribution is taxable as ordinary income.

Non-Natural Persons. Pursuant to Section 72(u) of the Code, a nonqualified Policy held by a taxpayer other than a natural person generally will not be treated as an annuity Policy under the Code; accordingly, an Owner who is not a natural person will recognize as ordinary income for a taxable year the excess, if any, of the Policy Value over the “investment in the contract.” There are some exceptions to this rule and a prospective purchaser of the Policy that is not a natural person should discuss these with a competent financial professional. A Policy owned by a trust using the grantor's social security number as its taxpayer identification number will be treated as owned by the grantor (natural person) for the purposes of our application of Section 72 of the Code. Consult a financial professional for more information on how this may impact Your Policy.

Different Individual Owner and Annuitant

If the Owner and Annuitant on the Policy are different individuals, there may be negative tax consequences to the Owner and/or beneficiaries under the Policy if the Annuitant predeceases the Owner including, but not limited, to the assessment of penalty tax and the loss of certain death benefit distribution options. You may wish to consult Your legal counsel or financial professional if You are considering designating a different individual as the Annuitant on Your Policy to determine the potential tax ramifications of such a designation.

Annuity Starting Date

This section makes reference to the annuity starting date as defined in Section 72 of the Code and the applicable regulations. Generally, the definition of annuity starting date will correspond with the definition of Annuity Commencement Date used in Your Policy and the dates will be the same. However, in certain circumstances, Your annuity starting date and Annuity Commencement

Date will not be the same date. If there is a conflict between the definitions, we will interpret and apply the definitions in order to ensure Your Policy maintains its status as an annuity contract for federal income tax purposes. You may wish to consult a financial professional for more information on when this issue may arise.

You should exercise care in setting Your Annuity Commencement Date. You should consult with a financial professional about the tax consequences with setting Your Annuity Commencement Date, especially if You are considering setting that date when the Annuitant will have attained an advanced age.

Taxation of Annuity Payments

Although the tax consequences may vary depending on the Annuity Payment Option You select, in general, for nonqualified and certain qualified policies, only a portion of the annuity payments You receive will be includable in Your gross income.

In general, the excludable portion of each annuity payment You receive will be determined as follows:

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Fixed payments-by dividing the “investment in the contract” on the annuity starting date by the total expected return under the Policy (determined under Treasury regulations) for the term of the payments. This is the percentage of each annuity payment that is excludable.

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Variable payments-by dividing the “investment in the contract” on the annuity starting date by the total number of expected periodic payments. This is the amount of each annuity payment that is excludable.

The remainder of each annuity payment is includable in gross income. Once the “investment in the contract” has been fully recovered, the full amount of any additional annuity payments is includable in gross income and taxed as ordinary income. The “investment in the contract” is generally equal to the premiums You pay for the contract, reduced by any amounts You have previously received from the contract that are excludible from gross income.

If You select more than one Annuity Payment Option, special rules govern the allocation of the Policy's entire “investment in the contract” to each such option, for purposes of determining the excludable amount of each payment received under that option. We advise You to consult a competent financial professional as to the potential tax effects of allocating amounts to any particular Annuity Payment Option.

If, after the annuity starting date, annuity payments stop because an Annuitant died, the excess (if any) of the “investment in the contract” as of the annuity starting date over the aggregate amount of annuity payments received that was excluded from gross income may possibly be allowable as a deduction on Your tax return.

Taxation of Surrenders and Withdrawals - Nonqualified Policies

When You surrender Your Policy, You are generally taxed on the amount that Your surrender proceeds exceeds the “investment in the contract”. The “investment in the contract” is generally equal to the premiums You pay for the Policy, reduced by any amounts You have previously received from the contract that are excludible from gross income. Withdrawals are generally treated first as taxable income to the extent of the excess in the Policy Value over the “investment in the contract.” Distributions taken under the systematic payout option are treated for tax purposes as withdrawals, not annuity payments. In general, loans, pledges, and collateral assignments as security for a loan are taxed in the same manner as partial withdrawals and surrenders. You may also be subject to current taxation if You make a gift of a nonqualified Policy without valuable consideration. All taxable amounts received under a Policy are subject to tax at ordinary rather than capital gain tax rates.

If Your Policy contains an Excess Interest Adjustment feature (also known as a market value adjustment), then Your Policy Value immediately before a Policy withdrawal (or transaction taxed like a withdrawal) may have to be increased by any positive Excess Interest Adjustments that result from the transaction. There is, however, no definitive guidance on the proper tax treatment of Excess Interest Adjustments, and You may want to discuss the potential tax consequences of an Excess Interest Adjustment with Your financial professional.

The Code also provides that amounts received from the Policy that are includible in gross income (including the taxable portion of some annuity payments) may be subject to a penalty tax. The amount of the penalty tax is equal to 10% of the amount that is includable in income. Some withdrawals and other amounts will be exempt from the penalty tax. Amounts received that are not subject to the penalty tax include, among others, any amounts: (1) paid on or after the taxpayer reaches age 59½; (2) paid after an Owner (or where the Owner is a non-natural person, an Annuitant) dies; (3) paid if the taxpayer becomes disabled (as that term is defined in the Code); (4) paid in a series of substantially equal payments made annually (or more frequently) over the life of the taxpayer or the joint life of the taxpayer and the taxpayer's designated beneficiary; (5) paid under an immediate annuity; or (6) which

come from premium payments made prior to August 14, 1982. Regarding the disability exception, because the Company cannot verify that the Owner is disabled, the Company will report such withdrawals to the IRS as early withdrawals with no known exception from the penalty tax.

Other exceptions may be applicable under certain circumstances and special rules may be applicable in connection with the exceptions enumerated above. You may wish to consult a financial professional for more information regarding the imposition of penalty tax.

Guaranteed Lifetime Withdrawal Benefits

For policies with a Guaranteed Lifetime Withdrawal Benefit the application of certain tax rules, particularly those rules relating to distributions from Your Policy, are not entirely clear. It is possible that the withdrawal base (with respect to the Guaranteed Lifetime Withdrawal Benefits) could be taken into account to determine the Policy Value that is used to calculate required distributions and the amount of the distribution that would be included in income. The proper treatment of the Income Enhancement Option under a Guaranteed Lifetime Withdrawal Benefit is unclear. It is possible that the IRS could determine that the benefit provides some form of long term care insurance. In that event, the Internal Revenue Service may determine the Income Enhancement Option is an incidental benefit with adverse consequences for qualification as an Individual Retirement Annuity, You could be treated as in receipt of some amount of income attributable to the value of the benefit even though You have not received a payment from Your Policy, and the amount of income attributable to guaranteed lifetime withdrawal payments could be affected. In addition, if the Income Enhancement Benefit causes an increase in payments calculated to meet the Required Minimum Distribution requirements it may violate the rules governing such distributions with adverse tax consequences. In view of this uncertainty, You should consult a financial professional with any questions.

Aggregation

All nonqualified deferred annuity policies that are issued by us (or our affiliates) to the same Owner (policyholder) during the same calendar year are treated as one annuity for purposes of determining the amount includable in the Owner's income when a taxable distribution (other than annuity payments) occurs. If You are considering purchasing multiple policies from us (or our affiliates) during the same calendar year, You may wish to consult with Your financial professional regarding how aggregation will apply to Your policies.

Tax-Free Exchanges of Nonqualified Policies

We may issue the nonqualified Policy in exchange for all or part of another annuity contract that You own. Such an exchange will be tax free if certain requirements are satisfied. If the exchange is tax free, Your investment in the Policy immediately after the exchange will generally be the same as that of the annuity contract exchanged, increased by any additional premium payment made as part of the exchange. Your Policy Value immediately after the exchange may exceed Your investment in the Policy. That excess may be includable in income should amounts subsequently be withdrawn or distributed from the Policy (e.g., as a withdrawal, surrender, annuity income payment or death benefit).

If You exchange part of an existing contract for the Policy, and within 180 days of the exchange You received a payment other than certain annuity payments (e.g., You take a withdrawal) from either contract, the exchange may not be treated as a tax free exchange. Rather, some or all of the amount exchanged into the Policy could be includible in Your income and subject to a 10% penalty tax.

You should consult Your financial professional in connection with an exchange of all or part of an annuity contract for the Policy, especially if You may take a withdrawal from either contract within 180 days after the exchange.

Medicare Tax

Distributions from nonqualified annuity policies are considered “investment income” for purposes of the Medicare tax on investment income. Thus, in certain circumstances, a 3.8% tax may be applied to some or all of the taxable portion of distributions (e.g., earnings) to individuals, trusts, and estates whose income exceeds certain threshold amounts. The Company is required to report distributions taken from nonqualified annuity policies as being potentially subject to this tax. While distributions from qualified policies are not subject to the tax, such distributions may be includable in income for purposes of determining whether certain Medicare Tax thresholds have been met. As such, distributions from Your qualified Policy could cause Your other investment income to be subject to the tax. Please consult a financial professional for more information.

Same Sex Relationships

Same sex couples have the right to marry in all states. The parties to each marriage that is valid under the law of any state will each be treated as a spouse as defined in this Policy. Individuals in other arrangements, such as civil unions, registered domestic partnerships, or other similar arrangements, that are treated as a valid marriage under the applicable state law, will each be treated as a spouse as defined in this Policy for state law purposes. However, individuals in other arrangements that are not recognized as marriage under the relevant state law, will not be treated as married or as spouses as defined in this Policy for federal tax purposes. Therefore, exercise of the spousal continuation provisions of this Policy or any riders by individuals who do not meet the definition of “spouse” may have adverse tax consequences and/or may not be permissible. Please consult a financial professional for more information on this subject.

Taxation of Death Benefit Proceeds

Amounts may be distributed from the Policy because of Your death or the death of the Annuitant. Generally, such amounts should be includable in the income of the recipient: (1) if distributed in a lump sum, these amounts are taxed in the same manner as a surrender; (2) if distributed via withdrawals, these amounts are taxed in the same manner as surrender; (3) or if distributed under an Annuity Payment Option, these amounts are taxed in the same manner as annuity payments.

Transfers, Assignments or Exchanges of Policies

A transfer of ownership or assignment of a Policy, the designation of an Annuitant or payee or other beneficiary who is not also the Owner, the exchange of a Policy and certain other transactions, or a change of Annuitant other than the Owner, may result in certain income or gift tax consequences to the Owner that are beyond the scope of this discussion. An Owner contemplating any such transaction or designation should contact a competent financial professional with respect to the potential tax effects.

Charges

It is possible that the IRS may take a position that fees for certain optional benefits (e.g., death benefits other than the Return of Premium death benefit) are deemed to be taxable distributions to You. In particular, the IRS may treat fees associated with certain optional benefits as a taxable withdrawal, which might also be subject to a tax penalty if the withdrawal occurs prior to age 59½. Although we do not believe that the fees associated with any optional benefit provided under the Policy should be treated as taxable withdrawals, the tax rules associated with these benefits are unclear, and we advise that You consult Your financial professional prior to selecting any optional benefit under the Policy.

Federal Estate, Gift and Generation-Skipping Transfer Taxes

The estate and gift tax unified credit basic exclusion amount is $13.61 million for 2024 and will be indexed for inflation (using C-CPI-U), for each taxable year, through January 1, 2026. The maximum rate is 40%.

There is no guarantee that the transfer tax exemptions and maximum rates will remain the same in the future. The uncertainty as to how the current law might be modified in the future underscores the importance of seeking guidance from a competent professional to help ensure that Your estate plan adequately addresses Your needs and that of Your beneficiaries under all possible scenarios.

Federal Estate Taxes. While no attempt is being made to discuss the Federal estate tax implications of the Policy in detail, a purchaser should keep in mind that the value of an annuity Policy owned by a decedent and payable to a beneficiary by virtue of surviving the decedent is included in the decedent's gross estate. Depending on the terms of the annuity Policy, the value of the annuity included in the gross estate may be the value of the lump sum payment payable to the designated beneficiary or the actuarial value of the payments to be received by the beneficiary. Consult an estate planning professional for more information.

Generation-Skipping Transfer Tax. Under certain circumstances, the Code may impose a “generation skipping transfer tax” when all or part of an annuity Policy is transferred to, or a death benefit is paid to, an individual two or more generations younger than the Owner. Regulations issued under the Code may require us to deduct the tax from Your Policy, or from any applicable payment, and pay it directly to the IRS.

Qualified Policies

The qualified Policy is designed for use with several types of tax-qualified retirement plans which are briefly described below. The tax rules applicable to participants and beneficiaries in tax-qualified retirement plans vary according to the type of plan and the terms and conditions of the plan. Special favorable tax treatment may be available for certain types of contributions and distributions. Adverse tax consequences may result from contributions in excess of specified limits, distributions prior to age 59½ (subject to certain exceptions), distributions that do not conform to specified commencement and minimum distribution rules, and in other specified

circumstances. The distribution rules under Section 72(s) of the Code do not apply to annuities provided under a plan described in Sections 401(a), 403(a), 403(b), 408 or 408A of the Code, but other similar rules may. Some retirement plans are subject to distribution and other requirements that are not incorporated into the policies or our Policy administration procedures. Owners, employers, participants, and beneficiaries are responsible for determining that contributions, distributions, and other transactions with respect to the policies comply with applicable law.

Distribution Requirements. Under Section 401(a) and/or Section 401(k) Contracts, the underlying tax-qualified plan may require payment of the death benefit in the form of a “qualified pre-retirement survivor annuity” or other payment method.

The information below generally applies to Owners who die after 2019. Post-death required distribution requirements are complex and frequently unclear. Please consult with Your financial professional for information relating to required post-death distributions for an Owner who died prior to 2020 or for information specific to Your own unique situation.

Upon a Owner’s death, if the Owner does not have a Beneficiary who is an individual, the Owner’s entire interest in the contract must generally be (1) distributed by the end of the calendar year ending five years after the date of death if the Owner died before the Owner was required to receive distributions under the contract or (2) at least as rapidly as the method being used as of the date of the Owner’s death if the Owner died after the Owner was required to begin receiving distributions under the contract. An exception may apply if the Beneficiary is a trust, and all of the trust Beneficiaries are individuals. If the Owner has a Beneficiary, who is an individual, but is not an eligible designated Beneficiary, the Owner’s entire interest in the contract must generally be distributed by the end of the calendar year ending ten years after the date of death.

If the Owner has a Beneficiary who is an eligible designated Beneficiary, the eligible designated Beneficiary may choose to receive the Owner’s interest under the contract either:

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by the end of the calendar year ending ten years after the date of death

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as an annuity over the life of the eligible designated Beneficiary or over a period not extending beyond the life expectancy of that Beneficiary, provided that such distributions begin within by the end of the calendar year following the calendar year of the Owner’s death.

An eligible designated Beneficiary is a Beneficiary who, meets any of the following criteria as of the date of the Owner’s death:

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is the Owner’s spouse

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the Owner’s child who has not reached the age of majority, but any remaining interest must be distributed within 10 years of when the child reaches the age of majority

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is disabled within the meaning of IRC section 72(m)(7)

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is chronically ill individual within the meaning of section 7702B(c)(2)

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is not more than 10 years younger than the Owner.

If the Beneficiary is the Owner’s spouse, distributions are not required to be made until the April 1st after the end of the calendar year in which the Owner would have attained age 72 if the spouse dies before distributions begin, the rules discussed above will apply as if the spouse were the Owner. If a spouse is the surviving Beneficiary, the spouse may elect to maintain an investment in the contract to the extent permitted by the Owner’s retirement arrangement.

Traditional Individual Retirement Annuities. In order to qualify as a traditional individual retirement annuity under Section 408(b) of the Code, a Policy must satisfy certain conditions: (i) the Owner must be the Annuitant; (ii) the Policy generally is not transferable by the Owner, e.g., the Owner may not designate a new Owner, designate a contingent Owner or assign the Policy as collateral security; (iii) subject to special rules, the total premium payments for any calendar year may not exceed the amount specified in the Code for the year, except in the case of a rollover amount or contribution under Section 402(c), 402(e)(6), 403(a)(4), 403(b)(8), 403(b)(10), 408(d)(3) or 457(e)(16) of the Code; (iv) annuity payments or withdrawals according to the requirements in the IRS regulations (minimum required distributions) must begin no later than April 1 of the calendar year following the calendar year in which the Annuitant attains age 72 (or age 70½ if the Annuitant attained 70½ before 1/1/2020); (v) an Annuity Payment Option with a period certain that will guarantee annuity payments beyond the life expectancy of the Annuitant and the beneficiary may not be selected; (vi) certain payments of death benefits must be made in the event the Annuitant dies prior to the distribution of the Policy Value; (vii) the entire interest of the Owner is non-forfeitable; and (viii) the premiums must not be fixed. Policies intended to qualify as traditional individual retirement annuities under Section 408(b) of the Code contain such provisions. Amounts in the individual retirement annuity (other than nondeductible contributions) generally are taxed only when distributed from the annuity. Distributions prior to age 59½ (unless certain exceptions apply) are subject to a 10% penalty tax.

Roth Individual Retirement Annuities (Roth IRA). The Roth IRA, under Section 408A of the Code, contains many of the same provisions as a traditional IRA. However, there are some differences. First, the contributions are not deductible and must be made in cash or as a rollover or transfer from another Roth IRA, a traditional IRA or other allowed qualified plan. A rollover from or conversion of an IRA to a Roth IRA may be subject to tax. The ability to make cash contributions to Roth IRAs is available to individuals with earned income and whose modified adjusted gross income is under a specified dollar amount for the year. Subject to special rules, the amount per individual that may be contributed to all IRAs (Roth and traditional) is an amount specified in the Code for the year. Secondly, the distributions are taxed differently. The Roth IRA offers tax-free distributions when taken 5 tax years after the first contribution to any Roth IRA of the individual and taken after one of the following: attaining age 59½, to pay for qualified first time home buyer expenses (lifetime maximum of $10,000), or due to death or disability. All other distributions are subject to income tax when taken from earnings and may be subject to a penalty tax unless an exception applies. Please note that specific tax ordering rules apply to Roth IRA distributions. Unlike the traditional IRA, there are no minimum required distributions during the Owner's lifetime; however, minimum required distributions at death are generally the same as for traditional IRAs.

The IRS has not reviewed this Policy for qualification as a Roth IRA, and has not addressed in a ruling of general applicability whether any death benefits available under the Policy comport with qualification requirements.

Section 403(b) Plans. Under Section 403(b) of the Code, payments made by public school systems and certain tax exempt organizations to purchase policies for their employees are generally excludable from the gross income of the employee, subject to certain limitations. However, such payments may be subject to Federal Insurance Contributions Act (FICA or Social Security) taxes. The Policy includes a death benefit that in some cases may exceed the greater of the premium payments or the Policy Value. Additionally, in accordance with the requirements of the Code, Section 403(b) annuities generally may not permit distribution of (i) elective contributions made in years beginning after December 31, 1988, and (ii) earnings on those contributions, and (iii) earnings on amounts attributed to elective contributions held as of the end of the last year beginning before January 1, 1989, unless certain events have occurred. Specifically distributions of such amounts will be allowed only upon the death of the employee, on or after attainment of age 59½, severance from employment, disability, or financial hardship, except that income attributable to elective contributions may not be distributed in the case of hardship. These rules may prevent the payment of guaranteed withdrawals under a Guaranteed Lifetime Withdrawal Benefit prior to age 59½. For policies issued after 2008, amounts attributable to non-elective contributions may be subject to distribution restrictions specified in the employer's section 403(b) plan. Employers using the Policy in connection with Section 403(b) plans may wish to consult with their financial professional.

Pursuant to tax regulations, we generally are required to confirm, with Your 403(b) plan sponsor or otherwise, that surrenders, loans or transfers You request from a 403(b) Policy comply with applicable tax requirements before we process Your request. We will defer such payments You request until all information required under the tax law has been received. By requesting a surrender or transfer, You consent to the sharing of confidential information about You, the Policy, and transactions under the Policy and any other 403(b) policies or accounts You have under the 403(b) plan among us, Your employer or plan sponsor, any plan administrator or record keeper, and other product providers.

Pension and Profit-Sharing Plans. Sections 401(a) and 403(a) of the Code permit corporate employers to establish various types of retirement plans for employees and self-employed individuals to establish qualified plans for themselves and their employees. Such retirement plans may permit the purchase of the policies to accumulate retirement savings. Adverse tax consequences to the plan, the participant or both may result if the Policy is assigned or transferred to any individual. Contributions to and distributions from such plans are limited by the Code and may be subject to penalties.

Deferred Compensation Plans. Section 457(b) of the Code, while not actually providing for a qualified plan as that term is normally used, provides for certain deferred compensation plans established and maintained by state and local governments (and their agencies and instrumentalities) and tax exempt organizations. Under such plans a participant may be able to specify the form of investment in which his or her participation will be made. For non-governmental Section 457(b) plans, all such investments, however, are typically owned by, and are subject to, the claims of the general creditors of the sponsoring employer. Depending on the terms of the particular plan, a non-government employer may be entitled to draw on deferred amounts for purposes unrelated to its Section 457(b) plan obligations. In general, all amounts received under a non-governmental Section 457 plan are taxable in the year paid (or in the year paid or made available in the case of a non-governmental 457(b) plan). Distributions from non-governmental 457(b) plans are subject to federal income tax withholding as wages, distributions from governmental 457(b) plans are subject to withholding as “eligible rollover distributions” as described in the section entitled “Withholding.” below. Contributions to and distributions from such plans are limited by the Code and may be subject to penalties. Deferred compensation plans of governments and tax-exempt entities that do not meet the requirements of Section 457(b) are taxed under Section 457(f), which means compensation deferred under the plan is included in gross income in the first year in which the compensation is not subject to substantial risk of forfeiture.

Ineligible Owners-Qualified

We currently will not issue new policies to/or for the following plans: 403(a), 403(b), 412(i)/412(e)(3), 419, 457 (we will in certain limited circumstances accept 457(f) plans), employee stock ownership plans, Keogh/H.R.-10 plans and any other types of plans at our sole discretion.

Taxation of Surrenders and Withdrawals - Qualified Policies

In the case of a withdrawal under a qualified Policy (other than from a deferred compensation plan under Section 457 of the Code), a pro rata portion of the amount You receive is taxable, generally based on the ratio of Your “investment in the contract” to Your total account balance or accrued benefit under the retirement plan. Your “investment in the contract” generally equals the amount of any non-deductible premium payments made by You or on Your behalf. If You do not have any non-deductible premium payments, Your investment in the contract will be treated as zero.

In addition, a penalty tax may be assessed on amounts surrendered from the Policy prior to the date You reach age 59½, unless You meet one of the exceptions to this rule which are similar to the penalty exceptions for distributions from nonqualified policies discussed above. However, the exceptions applicable for qualified policies differ from those provided to nonqualified policies. You may wish to consult a financial professional for more information regarding the application of these exceptions to Your circumstances. You may also be required to begin taking minimum distributions from the Policy by a certain date. The terms of the plan may limit the rights otherwise available to You under the Policy.

Qualified Plan Required Distributions

For qualified plans under Section 401(a), 403(a), 403(b), and 457, the Code requires that distributions generally must commence no later than the later of April 1 of the calendar year following the calendar year in which the Owner (or plan participant) (i) reaches age 72 (or 70½ if he/she attained 70½ prior to 1/1/2020) or (ii) retires, and must be made in a specified form or manner. If a participant is a “5 percent Owner” (as defined in the Code), or in the case of an IRA (other than a Roth IRA which is not subject to the lifetime required minimum distribution rules), distributions generally must begin no later than April 1 of the year following the calendar year in which the Owner (or plan participant) reaches age 72 (or 70½ if he/she attained 70½ prior to 1/1/2020). The actuarial present value of death and/or living benefit options and riders elected may need to be taken into account in calculating minimum distributions. Please consult with Your financial professional to learn more about an optional living or death benefit prior to purchase.

Each Owner is responsible for requesting distributions under the Policy that satisfy applicable tax rules. We do not attempt to provide more than general information about the use of the Policy with the various types of retirement plans. Purchasers of policies for use with any retirement plan should consult their legal counsel and financial professional regarding the suitability of the Policy.

The Code generally requires that interest in a qualified Policy be non-forfeitable.

You should consult Your legal counsel or financial professional if You are considering purchasing an enhanced death benefit or other optional rider, or if You are considering purchasing a Policy for use with any qualified retirement plan or arrangement.

Optional Living Benefits

For policies with a Guaranteed Lifetime Withdrawal Benefit the application of certain tax rules, particularly those rules relating to distributions from Your Policy, are not entirely clear. The tax rules for qualified policies may impact the value of these optional benefits. Additionally, the actions of the qualified plan as contract holder may cause the qualified plan participant to lose the benefit of the Guaranteed Lifetime Withdrawal Benefit. In view of this uncertainty, You should consult a financial professional before purchasing this Policy as a qualified Policy.

Withholding

The portion of any distribution under a Policy that is includable in gross income will be subject to federal income tax withholding unless the recipient of such distribution elects not to have federal income tax withheld. Election forms will be provided at the time distributions are requested or taken. The amount of withholding varies according to the type of distribution. The withholding rates applicable to the taxable portion of periodic payments (other than eligible rollover distributions) are the same as the withholding rates generally applicable to payments of wages. A 10% withholding rate applies to the taxable portion of non-periodic payments. Regardless of whether You elect not to have federal income tax withheld, You are still liable for payment of federal income tax on the taxable portion of the payment. For qualified policies taxable, “eligible rollover distributions” from Section 401(a) plans, Section 403(a) annuities, Section 403(b) tax-sheltered annuities, and governmental 457 plans are subject to a mandatory federal income tax withholding of 20%. An eligible rollover distribution is any distribution from such a plan, other than specified distributions such as distributions required by the Code, distributions in a specified annuity form or hardship distributions. The 20% withholding does

not apply, however, to nontaxable distributions or if (i) the employee (or employee's spouse or former spouse as beneficiary or alternate payee) chooses a “direct rollover” from the plan to a tax-qualified plan, IRA, Roth IRA or 403(b) tax-sheltered annuity or to a governmental 457 plan that agrees to separately account for rollover contributions; or (ii) a non-spouse beneficiary chooses a “direct rollover” from the plan to an IRA established by the direct rollover.

Annuity Purchases by Residents of Puerto Rico

The IRS has announced that income received by residents of Puerto Rico under life insurance or annuity policies issued by a Puerto Rico branch of a United States life insurance company is U.S.-source income that is generally subject to United States federal income tax.

Annuity Policies Purchased by Non-resident Aliens and Foreign Corporations

The discussion above provided general information (but not tax advice) regarding U.S. federal income tax consequences to annuity Owners that are U.S. persons. Taxable distributions made to Owners who are not U.S. persons will generally be subject to U.S. federal income tax withholding at a 30% rate, unless a lower treaty rate applies. In addition, distributions may be subject to state and/or municipal taxes and taxes that may be imposed by the Owner's country of citizenship or residence. Prospective foreign Owners are advised to consult with a qualified financial professional regarding U.S., state, and foreign taxation for any annuity Policy purchase.

Foreign Account Tax Compliance Act (“FATCA”)

If the payee of a distribution from the Policy is a foreign financial institution (“FFI”) or a non-financial foreign entity (“NFFE”) within the meaning of the Code as amended by the Foreign Account tax Compliance Act (“FATCA” ), the distribution could be subject to U.S. federal withholding tax on the taxable amount of the distribution at a 30% rate irrespective of the status of any beneficial Owner of the Policy or the distribution. The rules relating to FATCA are complex, and a financial professional should be consulted if an FFI or NFFE is or may be designated as a payee with respect to the Policy.

Possible Tax Law Changes

Although the likelihood and nature of legislative or regulatory changes is uncertain, there is always the possibility that the tax treatment of the Policy could change by legislation, regulation, or otherwise. You should consult a financial professional with respect to legal or regulatory developments and their effect on the Policy.

We have the right to modify the Policy to meet the requirements of any applicable laws or regulations, including legislative changes that could otherwise diminish the favorable tax treatment that annuity Owners currently receive.

OTHER INFORMATION

State Variations

The following section describes modifications to this prospectus required by one or more state insurance departments as of the date of this prospectus. Unless otherwise noted, variations apply to all forms of policies we issue. References to certain state's variations do not imply that we actually offer policies in each such state. These variations are subject to change without notice and additional variations may be imposed as specific states approve new riders. The Company will amend this prospectus upon notification of any additional variations received from one or more state insurance departments.

Arizona. Owners age 65 and above have a 30 day right to cancel. If canceled, the amount returned will include any fees and charges.

California. The Policy may be canceled by returning the Policy. A refund will be paid within 30 days from the date notice of cancellation was received and refund will include any fees or charges. Owners age 60 or above have the option to elect immediate investment in Investment Options of their choice, and receive Policy Value if they cancel; or, they may allocate the initial premium payment to the money market portfolio for 35 calendar days at the end of which the Policy Value is moved to the Investment Options of their choice, and they would receive return of premium if they cancel. Owners of the Transamerica Income EdgeSM rider, age 60 or above have the option to elect immediate investment consistent with the allocations permitted in the applicable Rate Sheet Prospectus Supplement, or, they may allocate the initial premium payment to the Stable Account as permitted in the applicable Rate Sheet Prospectus Supplement and the remaining premium to the money market portfolio for 35 calendar days (unless the Owner specifies that initial premium should be allocated to the underlying Subaccount(s)) at the end of which the Policy Value is moved to the Investment Options of their choice consistent with the allocations permitted in the applicable Rate Sheet Prospectus Supplement.

The Nursing Care and Terminal Condition and the Unemployment Waivers are not available. Retirement Income Max® 2.0 and Retirement Income Choice® 2.0 rider fees cannot be deducted from the Fixed Account if available. Restrictions on ownership change and assignments are not permitted. The Fixed Account is not available.

Connecticut. During the right to cancel period, prior to delivery of the Policy, the Owner will receive return of premium. The Unemployment Waiver is not available. There is no Excess Interest Adjustment upon Annuitization. Service charge cannot be assessed at time of surrender. Transfer restrictions apply if more than one transfer is made in a 30 day period. The Retirement Income Max® 2.0, Retirement Income Choice® 2.0 and Transamerica Income EdgeSM riders will not terminate for unapproved ownership changes and assignments, however, we have the right to reject certain ownership changes and assignments involving institutional investors, settlement companies or other similar organizations.

Florida. Owners have a 21 day right to cancel period and will receive return of premium. The Unemployment Waiver is not available. Excess Interest Adjustment is not applied upon Annuitization or death. The Annuity Commencement Date is not allowed until after the first Policy Year. The Retirement Income Max® 2.0 and Retirement Income Choice® 2.0 riders will terminate if the Policy to which these riders are attached has an ownership change or the Policy is assigned. The Transamerica Income EdgeSM rider will not terminate due to a misstatement of age.

Montana. The unemployment waiver is not available. The death benefit must be paid within 60 days and any interest due after 30 days.

New York. Under the right to cancel provision the premium payment allocated to the Fixed Account, if any, plus the Policy Value in the Separate Account, if any, including any fees and charges is returned. If the Policy is a replacement, the right to cancel period is extended to 60 days. Additional Death DistributionSM, Additional Death Distribution+SM, Unemployment Waiver and Telephone transactions are not available. There is no Excess Interest Adjustment. The death benefit payable during the accumulation phase is the greater of Policy Value or guaranteed minimum death benefit, if any. The Policy Value is used upon Annuitization. The Annuity Commencement Date cannot be earlier than the first Policy anniversary. Transamerica Income EdgeSM rider fees cannot be deducted from the Stable Account. Retirement Income Max® 2.0 and Retirement Income Choice® 2.0 rider fees cannot be deducted from the Fixed Account if available. Restrictions on ownership change and assignments are not permitted.

North Dakota. Right to cancel period is 20 days.

Sending Forms and Transaction Requests in Good Order

We cannot process Your requests for transactions relating to the Policy until they are received in good order. “Good order” means the actual receipt of the instructions relating to the requested transaction in writing (or, when appropriate, by telephone or electronically), along with all forms, information and supporting legal documentation necessary to effect the transaction. This information and documentation generally includes, to the extent applicable to the transaction: Your completed application; the Policy number; the transaction amount (in dollars or percentage terms); the names and allocations to and/or from the Subaccounts affected by the requested transaction; the dated signatures of all Owners (exactly as registered on the Policy) if necessary; Social Security Number or Taxpayer I.D.; and any other information or supporting documentation that we may require, including any spousal or joint Owner's consents. With respect to purchase requests, “good order” also generally includes receipt of sufficient funds to effect the purchase. We may, in our sole discretion, determine whether any particular transaction request is in good order, and we reserve the right to change or waive any good order requirements at any time.

“Received” or receipt in good order generally means that everything necessary must be received by us, at our Administrative Office specified in the Glossary of Terms. We reserve the right to reject electronic transactions that do not meet our requirements.

Regulatory Modifications to Policy

We reserve the right to amend the Policy or any riders attached thereto as necessary to comply with specific direction provided by state or federal regulators, through change of law, rule, regulation, bulletin, regulatory directives or agreements.

Anti-Money Laundering (AML) and Sanctions

The Company and the Separate Account are subject to laws and regulations designed to combat money laundering and terrorist financing. The Company, on its own behalf and on behalf of the Separate Account, has implemented and operates an anti-money laundering (“AML”) program. The Company shall not be held liable for any losses that an Owner, Annuitant, or beneficiary may incur as a result of actions taken to prevent suspected violations of AML laws, rules, and regulations.

The Company and the Separate Account are subject to the provisions of various sanctions programs administered and enforced by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). These programs prohibit financial institutions from doing business with certain identified enemies of the United States as set forth in various lists maintained by OFAC. Depending on

the program under which a transaction falls, financial institutions must either (i) reject and report the transaction, or (ii) block the transaction, place the funds or assets in a separate blocked transaction account, and report the matter to OFAC. In order to comply with OFAC requirements, the Company reviews applicants, Owners, and Annuitants against the OFAC list and stops processing and rejects any transaction from an individual or entity who is listed on the OFAC list. The Company only accepts premium payments that are not subject to sanctions and in United States currency.

If an Owner or Annuitant is subject to sanctions, the Company is required to block access to an Owner’s Policy and thereby refuse to pay any request for partial withdrawals, surrenders, or other distributions until permitted by OFAC. Further, if additional premium payments are received, we are required under applicable U.S. laws and regulations to place such funds in the blocked account as well. In addition, the Company may be required to block a beneficiary’s request for payment of death benefit proceeds. Blocking access may include transferring Cash Value and death benefit proceeds to the Fixed Account or money market subaccount until permitted by OFAC. The Company shall not be held liable for any losses that an Owner, Annuitant, or beneficiary may incur as a result of sanctions.

Mixed and Shared Funding

The underlying fund portfolios may serve as investment vehicles for variable life insurance policies, variable annuity policies and retirement plans (“mixed funding”) and shares of the underlying fund portfolios also may be sold to Separate Accounts of other insurance companies (“shared funding”). While we currently do not foresee any disadvantages to Owners and participants arising from either mixed or shared funding, it is possible that the interests of Owners of various policies and/or participants in various plans for which the underlying fund portfolios serve as investments might at some time be in conflict. We and each underlying fund portfolio’s Board of Directors intend to monitor events in order to identify any material conflicts and to determine what action, if any, to take. Such action could include the sale of underlying fund portfolio shares by one or more of the Separate Accounts, which could have adverse consequences. Such action could also include a decision that separate funds should be established for variable life and variable annuity Separate Accounts. In such an event, we would bear the attendant expenses, but Owners and plan participants would no longer have the economies of scale resulting from a larger combined fund. Please read the prospectuses for the underlying fund portfolios, which discuss the underlying fund portfolios’ risks regarding mixed and shared funding, as applicable. Please see Voting Rights section for how shares held by the Company would be voted.

Abandoned or Unclaimed Property

Every state has unclaimed property laws that generally provide for escheatment to the state of unclaimed property (including proceeds of annuity, life and other insurance policies) under various circumstances. In addition to the state unclaimed property laws, we may be required to escheat property pursuant to regulatory demand, finding, agreement or settlement. To help prevent such escheatment, it is important that You keep Your contact and other information on file with us up to date, including the names, contact information and identifying information for Owners, insureds, Annuitants, beneficiaries and other payees. Such updates should be communicated in a form and manner satisfactory to us.

Legal Proceedings

We, like other life insurance companies, are subject to regulatory and legal proceedings, in the ordinary course of our business. Such legal and regulatory matters include proceedings specific to us and other proceedings generally applicable to business practices in the industry in which we operate. In some lawsuits and regulatory proceedings involving insurers, substantial damages have been sought and/or material settlement payments have been made. Although the outcome of any litigation or regulatory proceeding cannot be predicted with certainty, at the present time, we believe that there are no pending or threatened proceedings or lawsuits that are likely to have a material adverse impact on the Separate Account, on TCI's ability to perform under its principal underwriting agreement, or on our ability to meet our obligations under the Policy.

Distribution of the Policies

Distribution and Principal Underwriting Agreement. We have entered into a principal underwriting agreement with our affiliate, Transamerica Capital, Inc. (TCI), for the distribution and sale of the policies. We pay commissions to TCI which are passed through to selling firms. (See below). We also pay TCI an “override” that is a percentage of total commissions paid on sales of our policies which is not passed through to the selling firms and we may reimburse TCI for certain expenses it incurs in order to pay for the distribution of the policies. TCI may market the policies through bank affiliated firms, national brokerage firms, regional and independent broker-dealers and independent financial planners.

Compensation to Broker-Dealers Selling the Policies. The policies are offered to the public through broker-dealers (“selling firms”) that are licensed under the federal securities laws; the selling firm and/or its affiliates are also licensed under state insurance laws. The selling firms have entered into written selling agreements with us and with TCI as principal underwriter for the policies. We pay commissions through TCI to the selling firms for their sales of the policies.

The selling firms are paid commissions for the promotion and sale of the policies according to one or more schedules. The amount and timing of commissions may vary depending on the selling agreement, but the maximum commission is 5% of premium payments (additional amounts may be paid as overrides to wholesalers).

To the extent permitted by Financial Industry Regulatory Authority (FINRA) rules, the Company and TCI may pay (or allow other broker-dealers to provide) promotional incentives or payments in the form of cash or non-cash compensation or reimbursement to some, but not all, selling firms and their sales representatives. These arrangements are described further below.

The sales representative who sells You the Policy typically receives a portion of the compensation we (and our affiliates) pay to the selling firms, depending on the agreement between the selling firm and its representative and the firm's internal compensation program. These programs may include other types of cash and non-cash compensation and other benefits. Ask Your sales representative for further information about the compensation Your sales representative, and the selling firm that employs Your sales representative, may receive in connection with Your purchase of a Policy. Also inquire about any compensation arrangements that we and our affiliates may have with the selling firm, including the conflicts of interests that such arrangements may create.

You should be aware that a selling firm or its sales representatives may receive different compensation or incentives for selling one product over another. In some cases, these differences may create an incentive for the selling firm or its sales representatives to recommend or sell the Policy to You. You may wish to take such incentives into account when considering and evaluating any recommendation relating to the policies.

Special Compensation Paid to Affiliated Firms. We and/or our affiliates provide paid-in capital to TCI and we or our affiliates may pay all or a portion of the cost of TCI's operating and other expenses, including costs for facilities, legal and accounting services, and other internal administrative functions. We and/or our affiliates also provide TCI with a percentage of total commissions paid on sales of our policies and provide TCI with capital payments that are not contingent on sales.

TCI's registered representatives and supervisors may receive non-cash compensation, such as attendance at conferences, seminars and trips (such as travel, lodging and meals in connection therewith), entertainment, merchandise and other similar items, payments, loans, loan forgiveness or loan guarantees.

Additional Compensation That We, TCI and/or Our Affiliates Pay to Selected Selling Firms. TCI, in connection with the sales of the policies, may pay certain selling firms additional cash amounts in order to receive enhanced marketing services and increased access to their sales representatives. In exchange for providing TCI with access to their distribution network, such selling firms may receive additional compensation or reimbursement for, among other things, the hiring and training of sales personnel, marketing, sponsoring of conferences, meetings, seminars, events, and/or other services they provide to us and our affiliates. To the extent permitted by applicable law, We, TCI and other parties may provide the selling firms with occasional gifts, meals, tickets or other non-cash compensation as an incentive to sell the policies. These special compensation arrangements are not offered to all selling firms and the terms of such arrangements may differ among selling firms.

During 2023, in general, payments calculated as a percentage of sales ranged from 10 basis point (0.1%) to 50 basis points (0.50%), payments calculated as a percentage of assets under management ranged from 2 basis points (0.02%) to 15 basis points (0.15%), and flat annual fees ranged from $5,000.00 to $500,000.00 (calculated after revenue sharing offsets for sales), which included at times payments for a series of meetings and/or events of other broker-dealers and banks.

As of December 31, 2023, TCI had revenue sharing agreements with more than 75 brokers and other financial intermediaries including, without limitation:

Ameriprise Financial Services, Inc.● Advisor Group, Inc./Osaic Wealth, Inc. (FSC Securities, Royal Alliance, SagePoint, Questar, Woodbury Financials Services, Securities America, Triad, American Portfolios, and Infinex Investments, Inc.)● Atria Wealth Solutions, Inc. (Cadaret Grant & Co., CUSO Financial, Next Financial, Sorrento and Western International Securities, Inc.) ● Avantax Investment Services, Inc. ● Cabot Lodge Securities, LLC ● Cambridge Investment Research ● Centaurus Financial, Inc. ● Cetera Financial Group, Inc. (Cetera Advisors, LLC, Cetera Advisor Networks, LLC, Cetera Financial Specialists, LLC, Cetera Investment Services, LLC, First Allied, Summit Brokerage Services, Inc.) ● Charles Schwab ● Citigroup Global Markets, Inc. ● Citizens Securities Inc.● Commonwealth Financial Network ● D.A. Davidson & Co., Inc. ● Edward Jones ● Equitable Advisors, LLC ● Equity Services, Inc. ● Financial Data Services, Inc. ● GWFS Equities Inc. ● Geneos Wealth Management ● Great West Financial ● Hantz Financial Services, Inc. ● Independent Financial Group, LLC ● Janney Montgomery Scott ● J.P. Morgan Securities LLC ● Kestra Investment Services ● LPL Financial Corp. ● Logan Group Securities ● Merrill Lynch ● Morgan Stanley

Smith Barney ● MML Investors Services ● Mutual of Omaha Investor Services Inc. ● National Financial Services, Inc. ● OneAmerica Securities Inc. ● Oppenheimer & Co. ● Park Avenue Securities ● Pershing LLC ● Principal Connectivity ● PNC Investments ● Pursche Kaplan Sterling ● Securian Financial Services Inc. ● Raymond James and Associates, Inc. ● Raymond James Financial Services, Inc. ● RBC Wealth Management ● Stifel Nicolaus & Company Inc ● TD Ameritrade ● UBS Financial Services Inc.● United Planners Financial Services of America ● US Bancorp Investments, Inc. ● Voya Financial Advisors, Inc. ● Wells Fargo Advisors, LLC and ● World Equity Group Inc.

For the calendar year ended December 31, 2023 TCI paid approximately $33.4 million to these brokers and other financial intermediaries in connection with revenue sharing arrangements. TCI expects to have revenue sharing arrangements with a number of brokers and other financial intermediaries in 2024, including some or all of the foregoing brokers and financial intermediaries, among others, on terms similar to those discussed above.

No specific charge is assessed directly to Owners or the Separate Account to cover commissions, non-cash compensation, and other incentives or payments described above. We do intend to recoup commissions and other sales expenses and incentives we pay, however, through fees and charges deducted under the Policy and other corporate revenue.

APPENDIX

PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY

The following is a list of current Portfolio Companies available under the Policy, which are subject to change as discussed in this prospectus. Depending on the optional benefits you choose, you may not be able to invest in certain Portfolio Companies.

Certain Subaccounts may not be available in all states, at all times or through all financial intermediaries. We may discontinue offering any Subaccount at any time. In some cases, a Subaccount not available through a financial intermediary may be obtained by contacting us directly. For more information on the options available for electing a Subaccount, please contact Your financial intermediary or our Administrative Office.

More information about the Portfolio Companies is available in the prospectuses for the Portfolio Companies, which may be amended from time to time and can be found online at http://dfinview.com/Transamerica/TAHD/89354G745?site=VAVUL. You can also request this information at no cost by calling our Administrative Office at (800)525-6205.

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

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser (1)	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	Average Annual Total Returns (as of 12/31/23)
Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser (1)	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	1 year	5 years	10 years
To maximize total return consistent with the Adviser's determination of reasonable risk.	AB Balanced Hedged Allocation Portfolio - Class B Advised by: AllianceBernstein L.P.	0.99%	0.20%	1.19%	12.66%	5.92%	5.04%
Long-term growth of capital.	AB Relative Value Portfolio - Class B Advised by: AllianceBernstein L.P.	0.87%	-	0.87%	11.72%	11.57%	9.05%
To provide high total return (including income and capital gains) consistent with preservation of capital over the long term.	American Funds - Asset Allocation FundSM - Class 2 Advised by: Capital Research and Management CompanySM	0.55%	0.30%	0.85%	14.27%	9.20%	7.25%
To provide growth of capital.	American Funds - Growth FundSM - Class 2 Advised by: Capital Research and Management CompanySM	0.59%	0.30%	0.89%	38.49%	18.68%	14.36%
To achieve long-term growth of capital and income.	American Funds - Growth-Income FundSM - Class 2 Advised by: Capital Research and Management CompanySM	0.53%	0.30%	0.83%	26.14%	13.36%	10.91%
To achieve long-term growth of capital.	American Funds - International FundSM - Class 2 Advised by: Capital Research and Management CompanySM	0.78%	0.30%	1.08%	15.84%	4.83%	3.41%
To provide as high a level of current income as is consistent with the preservation of capital.	American Funds - The Bond Fund of AmericaSM - Class 2 Advised by: Capital Research and Management CompanySM	0.63%	0.30%	0.93%	5.02%	1.89%	2.08%
Seeks income and capital growth consistent with reasonable risk.	Fidelity® VIP Balanced Portfolio - Service Class 2 Advised by: Fidelity Management & Research Company	0.69%	-	0.69%	21.29%	12.16%	8.81%
Seeks long-term capital appreciation.	Fidelity® VIP Contrafund® Portfolio - Service Class 2 Advised by: Fidelity Management & Research Company	0.81%	-	0.81%	33.12%	16.36%	11.33%

PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY — (Continued)

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser (1)	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	Average Annual Total Returns (as of 12/31/23)
Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser (1)	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	1 year	5 years	10 years
Seeks long-term growth of capital.	Fidelity® VIP Mid Cap Portfolio - Service Class 2 Advised by: Fidelity Management & Research Company	0.82%	-	0.82%	14.80%	12.17%	7.85%
Seeks capital appreciation.	Fidelity® VIP Value Strategies Portfolio - Service Class 2 Advised by: Fidelity Management & Research Company	0.85%	-	0.85%	20.61%	16.63%	9.10%
The highest total return, composed of current income and capital appreciation, as is consistent with prudent investment risk.	State Street Total Return V.I.S. Fund - Class 3 Advised by: SSGA Funds Management, Inc.	0.90%	0.20%	1.10%	15.21%	5.90%	4.66%
Seeks long-term capital appreciation and current income.	Transamerica 60/40 Allocation VP - Service Class Advised by: Transamerica Asset Management, Inc.	0.90%	-	0.90%	15.95%	8.88%	N/A
Seeks maximum total return consistent with preservation of capital and prudent investment management.	Transamerica Aegon Bond VP – Service Class Sub-Advised by: Aegon USA Investment Management, LLC	0.78%	-	0.78%	6.18%	0.73%	1.44%
Seeks total return, consisting of current income and capital appreciation.	Transamerica Aegon Core Bond VP - Service Class Sub-Advised by: Aegon USA Investment Management, LLC	0.75%	-	0.75%	5.78%	1.06%	1.60%
Seeks a high level of current income by investing in high-yield debt securities.	Transamerica Aegon High Yield Bond VP - Service Class Sub-Advised by: Aegon USA Investment Management, LLC	0.90%	-	0.90%	10.87%	4.47%	4.00%
Seeks total return gained from the combination of dividend yield, growth of dividends and capital appreciation.	Transamerica Aegon Sustainable Equity Income VP - Service Class Sub-Advised by: Aegon Asset Management UK plc (“AAM”)	0.98%	-	0.98%	6.00%	5.44%	5.13%
Seeks to provide as high a level of total return as is consistent with prudent investment strategies.	Transamerica Aegon U.S. Government Securities VP - Service Class Sub-Advised by: Aegon USA Investment Management, LLC	0.83%	-	0.83%	3.69%	0.25%	0.79%
Seeks to provide total return (including income and capital gains) consistent with preservation of capital over the long term while seeking to manage volatility and provide downside protection.	Transamerica American Funds Managed Risk VP - Service Class Sub-Advised by: Milliman Financial Risk Management LLC	1.10%	-	1.10%	10.39%	6.32%	N/A
Seeks as high a level of current income as is consistent with preservation of capital and liquidity.	Transamerica BlackRock Government Money Market VP - Service Class(2) Sub-Advised by: BlackRock Investment Management, LLC	0.54%	-	0.54%	4.66%	1.58%	0.87%
Seeks current income and preservation of capital.	Transamerica BlackRock iShares Active Asset Allocation - Conservative VP - Service Class Sub-Advised by: BlackRock Investment Management, LLC	0.92%	-	0.92%	9.96%	3.16%	2.79%

PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY — (Continued)

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser (1)	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	Average Annual Total Returns (as of 12/31/23)
Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser (1)	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	1 year	5 years	10 years
Seeks capital appreciation and current income.	Transamerica BlackRock iShares Active Asset Allocation - Moderate VP - Service Class Sub-Advised by: BlackRock Investment Management, LLC	0.88%	-	0.88%	13.37%	3.15%	2.73%
Seeks capital appreciation with current income as secondary objective.	Transamerica BlackRock iShares Active Asset Allocation - Moderate Growth VP - Service Class Sub-Advised by: BlackRock Investment Management, LLC	0.91%	-	0.91%	17.62%	2.43%	2.30%
Seeks capital appreciation and income.	Transamerica BlackRock iShares Dynamic Allocation - Balanced VP - Service Class Sub-Advised by: BlackRock Investment Management, LLC	0.89%	-	0.89%	12.66%	3.61%	3.01%
Seeks capital appreciation and income.	Transamerica BlackRock iShares Dynamic Allocation - Moderate Growth VP - Service Class Sub-Advised by: BlackRock Investment Management, LLC	0.89%	-	0.89%	17.28%	4.96%	3.63%
Seeks long term capital appreciation and capital preservation.	Transamerica BlackRock iShares Edge 40 VP - Service Class Sub-Advised by: BlackRock Investment Management, LLC	0.71%	-	0.71%	9.07%	4.46%	3.37%
Seeks long-term capital appreciation and capital preservation.	Transamerica BlackRock iShares Edge 50 VP - Service Class Sub-Advised by: BlackRock Investment Management, LLC	0.69%	-	0.69%	9.79%	5.19%	N/A
Seeks long-term capital appreciation and capital preservation as a secondary objective.	Transamerica BlackRock iShares Edge 75 VP - Service Class Sub-Advised by: BlackRock Investment Management, LLC	0.73%	-	0.73%	12.09%	7.36%	N/A
Seeks long-term capital appreciation.	Transamerica BlackRock iShares Edge 100 VP - Service Class Sub-Advised by: BlackRock Investment Management, LLC	0.81%	-	0.81%	14.47%	9.34%	N/A
Seeks a combination of capital appreciation and income.	Transamerica BlackRock iShares Tactical - Balanced VP - Service Class(3) Sub-Advised by: Pacific Investment Management Company LLC	0.89%		0.89%	10.66%	4.27%	3.59%
Seeks a combination of capital appreciation and income.	Transamerica BlackRock iShares Tactical - Conservative VP - Service Class(4) Sub-Advised by: Pacific Investment Management Company LLC	0.92%		0.92%	7.24%	3.61%	3.40%
Seeks a combination of capital appreciation and income.	Transamerica BlackRock iShares Tactical - Growth VP - Service Class(5) Sub-Advised by: Pacific Investment Management Company LLC	0.93%		0.93%	13.94%	6.23%	4.44%

PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY — (Continued)

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser (1)	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	Average Annual Total Returns (as of 12/31/23)
Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser (1)	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	1 year	5 years	10 years
Seeks to maximize total return.	Transamerica BlackRock Real Estate Securities VP - Service Class Sub-Advised by: BlackRock Investment Management, LLC	1.15%	-	1.15%	13.15%	4.85%	3.59%
Seeks capital appreciation with current income as a secondary objective.	Transamerica BlackRock Tactical Allocation VP - Service Class Sub-Advised by: BlackRock Investment Management, LLC	1.02%	-	1.02%	14.88%	6.54%	4.90%
Seeks to balance capital appreciation and income.	Transamerica Goldman Sachs Managed Risk - Balanced ETF VP - Service Class Sub-Advised by: Goldman Sachs Asset Management, L.P.	0.64%	-	0.64%	13.20%	5.04%	3.97%
Seeks current income and preservation of capital.	Transamerica Goldman Sachs Managed Risk - Conservative ETF VP - Service Class Sub-Advised by: Goldman Sachs Asset Management, L.P.	0.66%	-	0.66%	10.59%	3.35%	3.22%
Seeks capital appreciation as a primary objective and income as a secondary objective.	Transamerica Goldman Sachs Managed Risk - Growth ETF VP - Service Class Sub-Advised by: Goldman Sachs Asset Management, L.P.	0.67%	-	0.67%	17.68%	7.38%	5.13%
Seeks long-term capital appreciation.	Transamerica Great Lakes Advisors Large Cap Value VP - Service Class(6) Sub-Advised by: Great Lakes Advisors LLC	0.97%	-	0.97%	12.78%	9.66%	N/A
Seeks long-term capital appreciation.	Transamerica International Focus VP - Service Class Sub-Advised by: Epoch Investment Partners, Inc.	1.10%	-	1.10%	12.27%	8.75%	4.09%
Seeks long-term capital growth, consistent with preservation of capital and balanced by current income.	Transamerica Janus Balanced VP - Service Class Sub-Advised by: Janus Henderson Investors US LLC	0.99%	-	0.99%	15.01%	9.00%	7.27%
Seeks long-term capital appreciation.	Transamerica Janus Mid-Cap Growth VP - Service Class Sub-Advised by: Janus Henderson Investors US LLC	1.11%	-	1.11%	16.80%	12.97%	7.98%
Seeks current income and preservation of capital.	Transamerica JPMorgan Asset Allocation - Conservative VP – Service Class Sub-Advised by: J.P. Morgan Investment Management Inc.	0.99%	-	0.99%	6.83%	3.76%	3.04%
Seeks current income and preservation of capital.	Transamerica JPMorgan Asset Allocation - Growth VP – Service Class Sub-Advised by: J.P. Morgan Investment Management Inc.	1.11%	-	1.11%	20.00%	11.61%	7.40%

PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY — (Continued)

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser (1)	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	Average Annual Total Returns (as of 12/31/23)
Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser (1)	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	1 year	5 years	10 years
Seeks capital appreciation and current income.	Transamerica JPMorgan Asset Allocation - Moderate VP – Service Class Sub-Advised by: J.P. Morgan Investment Management Inc.	1.02%	-	1.02%	8.86%	5.31%	4.13%
Seeks capital appreciation with current income as a secondary objective.	Transamerica JPMorgan Asset Allocation - Moderate Growth VP – Service Class Sub-Advised by: J.P. Morgan Investment Management Inc.	1.08%	-	1.08%	11.93%	7.59%	5.41%
Seeks to earn a total return modestly in excess of the total return performance of the S&P 500® (including the reinvestment of dividends) while maintaining a volatility of return similar to the S&P 500®.	Transamerica JPMorgan Enhanced Index VP – Service Class Sub-Advised by: J.P. Morgan Investment Management Inc.	0.87%	-	0.87%	27.39%	16.10%	11.67%
Seeks capital appreciation with current income as a secondary objective.	Transamerica JPMorgan International Moderate Growth VP – Service Class Sub-Advised by: J.P. Morgan Investment Management Inc.	1.14%	-	1.14%	8.70%	5.68%	3.33%
Seeks current income and preservation of capital.	Transamerica JPMorgan Tactical Allocation VP - Service Class Sub-Advised by: J.P. Morgan Investment Management Inc.	1.02%	-	1.02%	8.57%	3.90%	3.44%
Seeks high total return through the combination of income and capital appreciation.	Transamerica Madison Diversified Income VP - Service Class Sub-Advised by: Madison Asset Management. LLC	1.08%	-	1.08%	3.97%	4.51%	4.38%
Seeks capital appreciation.	Transamerica Market Participation Strategy VP - Service Class Sub-Advised by: PGIM Quantitative Solutions LLC	0.98%	-	0.98%	11.55%	9.06%	6.12%
Seeks high total return..	Transamerica Morgan Stanley Global Allocation VP - Service Class Sub-Advised by: Morgan Stanley Investment Management Inc.	1.28%	-	1.28%	13.69%	7.12%	4.51%
Seeks to provide capital appreciation and income while seeking to manage volatility.	Transamerica Morgan Stanley Global Allocation Managed Risk - Balanced VP - Service Class Sub-Advised by: Milliman Financial Risk Management LLC	1.45%	-	1.45%	9.00%	3.64%	N/A
Seeks to track the investment results of an index composed of large- and mid-capitalization developed market equities, excluding the U.S. and Canada.	Transamerica MSCI EAFE Index VP - Service Class Sub-Advised by: SSGA Funds Management, Inc.	0.61%	0.15%	0.76%	17.46%	7.80%	N/A
Seeks to provide a high total investment return through investments in a broadly diversified portfolio of stock, bonds and money market instruments.	Transamerica Multi-Managed Balanced VP – Service Class Sub-Advised by: J.P. Morgan Investment Management Inc. and Aegon USA Investment Management, LLC	0.89%	-	0.89%	18.44%	10.16%	7.75%

PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY — (Continued)

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser (1)	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	Average Annual Total Returns (as of 12/31/23)
Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser (1)	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	1 year	5 years	10 years
Seeks maximum real return, consistent with appreciation of capital.	Transamerica PineBridge Inflation Opportunities VP - Service Class Sub-Advised by: PineBridge Investments LLC	0.78%	-	0.78%	5.44%	2.87%	2.00%
Seeks to provide investment results that, before expenses, correspond generally to the price and yield performance of the S&P 500® Index.	Transamerica S&P 500 Index VP - Service Class Sub-Advised by: SSGA Funds Management, Inc.	0.39%	0.15%	0.54%	25.73%	15.20%	N/A
Seeks to maximize total return.	Transamerica Small/Mid Cap Value VP – Service Class Sub-Advised by: Systematic Financial Management L.P. & Thompson, Siegel & Walmsley LLC	1.07%	-	1.07%	12.15%	11.19%	7.88%
Seeks long-term growth of capital by investing primarily in common stocks of small growth companies.	Transamerica T. Rowe Price Small Cap VP – Service Class Sub-Advised by: T. Rowe Price Associates, Inc.	1.09%	-	1.09%	20.88%	11.15%	8.74%
Seeks maximum long-term total return, consistent with reasonable risk to principal, by investing in a diversified portfolio of common stocks of primarily non-U.S. issuers.	Transamerica TS&W International Equity VP – Service Class Sub-Advised by: Thompson, Siegel & Walmsley LLC	1.11%	-	1.11%	15.26%	7.39%	3.59%
Seeks growth from capital appreciation.	Transamerica TS&W Mid Cap Value Opportunities VP–Service Class(7) Sub-Advised by: J.P. Morgan Investment Management Inc.	1.02%	-	1.02%	10.57%	10.68%	7.74%
Seeks to maximize long-term growth.	Transamerica WMC US Growth VP – Service Class(8) Sub-Advised by: Wellington Management Company, LLP	0.91%	-	0.91%	41.72%	17.45%	13.31%

(1)

Some Subaccounts may be available for certain policies and may not be available for all policies. You should work with your registered representative to decide which Subaccount(s) may be appropriate for you based on a thorough analysis of your particular insurance needs, financial objective, investment goals, time horizons, and risk tolerance.

(2)

There can be no assurance that any money market portfolio offered under this Policy will be able to maintain a stable net asset value per share during extended periods of low interest rates, and partly as a result of Policy charges, the yield on the money market Subaccount may become extremely low and possibly negative.

(3)

Effective on or about May 1, 2024 Transamerica PIMCO Tactical - Balanced VP was renamed Transamerica BlackRock iShares Tactical - Balanced VP and the sub-advisor was changed to BlackRock Investment Management, LLC.

(4)

Effective on or about May 1, 2024 Transamerica PIMCO Tactical - Conservative VP was renamed Transamerica BlackRock iShares Tactical - Conservative VP and the sub-advisor was changed to BlackRock Investment Management, LLC.

(5)

Effective on or about May 1, 2024 Transamerica PIMCO Tactical - Growth VP was renamed Transamerica BlackRock iShares Tactical - Balanced VP and the sub-advisor was changed to BlackRock Investment Management, LLC.

(6)

Effective on or about May 1, 2023 Transamerica Rothschild & Co. Large Cap Value VP was renamed Transamerica Great Lakes Advisors Large Cap Value VP. Effective April 3, 2023 the sub-advisor was changed from Rothschild & Co. to Great Lakes Advisors LLC.

(7)

Effective on or about May 1, 2024 Transamerica JPMorgan Mid Cap Value VP was renamed Transamerica TS& W Mid Cap Value Opportunities VP and the sub-advisor was changed to Thompson, Siegel & Walmsley LLC.

(8)

Effective on or about May 1, 2023 Transamerica Morgan Stanley Capital Growth VP was substituted with Transamerica WMC US Growth VP. The sub-advisor of the acquiring fund is Wellington Management Company, LLP.

APPENDIX

Designated Investment Options

The table below identifies the Designated Investment Options available for use with the Guaranteed Minimum Death Benefits and our Guaranteed Lifetime Withdrawal Benefits except for the Transamerica Income EdgeSM rider. See Appendix - Transamerica Income EdgeSM Investment Options.

	Return of Premium Death Benefit	Annual Step-Up Death Benefit	Retirement Income Max® 2.0 Rider	Retirement Income Max® 2.0 Rider	Retirement Income Max® 2.0 Rider	Retirement Income Choice® 2.0 Rider	Retirement Income Choice® 2.0 Rider	Retirement Income Choice® 2.0 Rider
Subaccounts			Prior to 2/1/18	2/1/18 to 1/30/20	After 1/31/20	Prior to 2/28/18	3/1/18 to 8/31/20	9/1/20 and After Group A, B or C
AB Balanced Hedged Allocation Portfolio - Class B	√	√				A	A	B
AB Relative Value Portfolio - Class B	√	√					A	A
American Funds - Asset Allocation FundSM - Class 2	√	√					A	B
American Funds - The Bond Fund of AmericaSM - Class 2	√	√	√	√	√	C	A	C
American Funds - Growth FundSM - Class 2	√	√					A	A
American Funds - Growth-Income FundSM - Class 2	√	√					A	A
American Funds - International FundSM - Class 2	√	√					A	A
Fidelity® VIP Balanced Portfolio - Service Class 2	√	√					A	B
Fidelity® VIP Contrafund® Portfolio - Service Class 2	√	√					A	A
Fidelity® VIP Mid Cap Portfolio - Service Class 2	√	√					A	A
Fidelity® VIP Value Strategies Portfolio - Service Class 2	√	√					A	A
State Street Total Return V.I.S. Fund - Class 3	√	√				A	A	B
TA 60/40 Allocation - Service Class	√	√				A	A	B
TA Aegon Bond - Service Class	√	√	√	√	√	C	A	C
TA Aegon Core Bond - Service Class	√	√	√	√	√	C	A	C
TA Aegon High Yield Bond - Service Class	√	√					A	B
TA Aegon Sustainable Equity Income - Service Class	√	√					A	A
TA Aegon U.S. Government Securities - Service Class	√	√	√	√	√	C	A	C
TA American Funds Managed Risk - Balanced - Service Class(1)	√	√		√	√	B	A	B
TA BlackRock Government Money Market - Service Class	√	√	√	√	√	C	A	C
TA BlackRock iShares Active Asset Allocation - Conservative - Service Class(1)	√	√	√	√	√	C	A	B
TA BlackRock iShares Active Asset Allocation - Moderate - Service Class(1)	√	√	√	√	√	B	A	B
TA BlackRock iShares Active Asset Allocation - Moderate Growth - Service Class(1)	√	√				A	A	B
TA BlackRock iShares Dynamic Allocation - Balanced - Service Class	√	√	√	√	√	B	A	B
TA BlackRock iShares Dynamic Allocation - Moderate Growth - Service Class(1)	√	√				A	A	B
TA BlackRock iShares Edge 40- Service Class	√	√		√	√	C	A	B
TA BlackRock iShares Edge 50 - Service Class	√	√		√	√	B	A	B

Designated Investment Options — (Continued)

	Return of Premium Death Benefit	Annual Step-Up Death Benefit	Retirement Income Max® 2.0 Rider	Retirement Income Max® 2.0 Rider	Retirement Income Max® 2.0 Rider	Retirement Income Choice® 2.0 Rider	Retirement Income Choice® 2.0 Rider	Retirement Income Choice® 2.0 Rider
Subaccounts			Prior to 2/1/18	2/1/18 to 1/30/20	After 1/31/20	Prior to 2/28/18	3/1/18 to 8/31/20	9/1/20 and After Group A, B or C
TA BlackRock iShares Edge 75 - Service Class	√	√				A	A	B
TA BlackRock iShares Edge 100 - Service Class	√	√					A	A
TA BlackRock iShares Tactical - Balanced - Service Class	√	√				B	A	B
TA BlackRock iShares Tactical - Conservative - Service Class	√	√	√	√	√	C	A	B
TA BlackRock iShares Tactical - Growth - Service Class	√	√				A	A	B
TA BlackRock Real Estate Securities - Service Class	√	√					A	A
TA BlackRock Tactical Allocation - Service Class	√	√				B	A	B
TA Goldman Sachs Managed Risk - Balanced ETF - Service Class(1)	√	√	√	√	√	B	A	B
TA Goldman Sachs Managed Risk - Conservative ETF - Service Class(1)	√	√	√	√	√	C	A	B
TA Goldman Sachs Managed Risk - Growth ETF - Service Class(1)	√	√				A	A	B
TA Great Lakes Advisors Large Cap Value - Service Class	√	√					A	A
TA International Focus - Service Class	√	√					A	A
TA Janus Balanced - Service Class	√	√				A	A	B
TA Janus Mid-Cap Growth - Service Class	√	√					A	A
TA JPMorgan Asset Allocation - Conservative - Service Class(1)	√	√	√	√	√	C	A	B
TA JPMorgan Asset Allocation - Growth - Service Class	√	√					A	A
TA JPMorgan Asset Allocation - Moderate - Service Class(1)	√	√		√	√	B	A	B
TA JPMorgan Asset Allocation - Moderate Growth - Service Class(1)	√	√				A	A	B
TA JPMorgan Enhanced Index - Service Class	√	√					A	A
TA JPMorgan International Moderate Growth - Service Class(1)	√	√				A	A	B
TA JPMorgan Tactical Allocation - Service Class	√	√	√	√	√	C	A	B
TA Madison Diversified Income - Service Class	√	√	√	√	√	B	A	B
TA Market Participation Strategy - Service Class	√	√				B	A	B
TA Morgan Stanley Global Allocation - Service Class	√	√				A	A	B
TA Morgan Stanley Global Allocation Managed Risk - Balanced - Service Class(1)	√	√		√	√	B	A	B
TA MSCI EAFE Index - Service Class	√	√					A	A
TA Multi-Managed Balanced - Service Class	√	√				A	A	B
TA PineBridge Inflation Opportunities - Service Class	√	√	√	√	√	C	A	C
TA S&P 500 Index - Service Class	√	√					A	A

Designated Investment Options — (Continued)

	Return of Premium Death Benefit	Annual Step-Up Death Benefit	Retirement Income Max® 2.0 Rider	Retirement Income Max® 2.0 Rider	Retirement Income Max® 2.0 Rider	Retirement Income Choice® 2.0 Rider	Retirement Income Choice® 2.0 Rider	Retirement Income Choice® 2.0 Rider
Subaccounts			Prior to 2/1/18	2/1/18 to 1/30/20	After 1/31/20	Prior to 2/28/18	3/1/18 to 8/31/20	9/1/20 and After Group A, B or C
TA Small Mid Cap Value - Service Class	√	√					A	A
TA T. Rowe Price Small Cap - Service Class	√	√					A	A
TA TS&W International Equity - Service Class	√	√					A	A
TA TS&W Mid Cap Value Opportunities - Service Class	√	√					A	A
TA WMC US Growth - Service Class	√	√					A	A
Fixed Account	√	√	√	√	√	C	A	C

(1) This Subaccount invests in an underlying fund portfolio that utilized a volatility management strategy as part of its investment objective and/or principal investment strategy. See Investment Restrictions earlier in the prospectus for information on how volatility management strategies may impact Your Policy Value in certain optional riders.

Certain designated Investment Options may not be available in all states, at all times or through all financial intermediaries. We may discontinue offering any designated Investment Option at any time. In some cases, a designated Investment Option not available through a financial intermediary may be obtained by contacting us directly. For more information on the options available for electing a designated Investment Option, please contact your financial intermediary or our Administrative Office.

APPENDIX

TRANSAMERICA INCOME EDGESM Investment Options

The table below identifies the Select Investment Options and Flexible Investment Options available for use with the Transamerica Income EdgeSM rider.

	Select Investment Options	Select Investment Options	Flexible Investment Options	Flexible Investment Options
Subaccounts	Before 1/31/20	Post 1/31/20	Before 1/31/20	Post 1/31/20
AB Balanced Hedged Allocation Portfolio - Class B			√	√
AB Relative Value Portfolio - Class B			√	√
American Funds - Asset Allocation FundSM - Class 2			√	√
American Funds - The Bond Fund of AmericaSM - Class 2	√	√
American Funds - Growth FundSM - Class 2			√	√
American Funds - Growth-Income FundSM - Class 2			√	√
American Funds - International FundSM - Class 2			√	√
Fidelity® VIP Balanced Portfolio - Service Class 2			√	√
Fidelity® VIP Contrafund® Portfolio - Service Class 2			√	√
Fidelity® VIP Mid Cap Portfolio - Service Class 2			√	√
Fidelity® VIP Value Strategies Portfolio - Service Class 2			√	√
State Street Total Return V.I.S. Fund - Class 3			√	√
TA 60/40 Allocation - Service Class			√	√
TA Aegon Bond - Service Class	√	√
TA Aegon Core Bond - Service Class	√	√
TA Aegon High Yield Bond - Service Class			√	√
TA Aegon Sustainable Equity Income - Service Class			√	√
TA Aegon U.S. Government Securities - Service Class	√	√
TA American Funds Managed Risk - Balanced - Service Class(1)			√	√
TA BlackRock Government Money Market - Service Class	√	√
TA BlackRock iShares Active Asset Allocation - Conservative - Service Class(1)			√	√
TA BlackRock iShares Active Asset Allocation - Moderate - Service Class(1)			√	√
TA BlackRock iShares Active Asset Allocation - Moderate Growth - Service Class(1)			√	√
TA BlackRock iShares Dynamic Allocation - Balanced - Service Class(1)			√	√
TA BlackRock iShares Dynamic Allocation - Moderate Growth - Service Class(1)			√	√
TA BlackRock iShares Edge 40- Service Class			√	√
TA BlackRock iShares Edge 50 - Service Class			√	√
TA BlackRock iShares Edge 75 - Service Class			√	√
TA BlackRock iShares Edge 100 - Service Class			√	√
TA BlackRock iShares Tactical - Balanced - Service Class			√	√
TA BlackRock iShares Tactical - Conservative - Service Class			√	√
TA BlackRock iShares Tactical - Growth - Service Class			√	√
TA BlackRock Real Estate Securities - Service Class			√	√
TA BlackRock Tactical Allocation - Service Class(1)			√	√
TA Goldman Sachs Managed Risk - Balanced ETF - Service Class(1)			√	√
TA Goldman Sachs Managed Risk - Conservative ETF - Service Class(1)			√	√

TRANSAMERICA INCOME EDGESM Investment Options — (Continued)

	Select Investment Options	Select Investment Options	Flexible Investment Options	Flexible Investment Options
Subaccounts	Before 1/31/20	Post 1/31/20	Before 1/31/20	Post 1/31/20
TA Goldman Sachs Managed Risk - Growth ETF - Service Class(1)			√	√
TA Great Lakes Advisors Large Cap Value - Service Class			√	√
TA International Focus - Service Class			√	√
TA Janus Balanced - Service Class			√	√
TA Janus Mid-Cap Growth - Service Class			√	√
TA JPMorgan Asset Allocation - Conservative - Service Class(1)			√	√
TA JPMorgan Asset Allocation - Growth - Service Class			√	√
TA JPMorgan Asset Allocation - Moderate - Service Class(1)			√	√
TA JPMorgan Asset Allocation - Moderate Growth - Service Class(1)			√	√
TA JPMorgan Enhanced Index - Service Class			√	√
TA JPMorgan International Moderate Growth - Service Class(1)			√	√
TA JPMorgan Tactical Allocation - Service Class			√	√
TA Madison Diversified Income - Service Class			√	√
TA Market Participation Strategy - Service Class(1)			√	√
TA Morgan Stanley Global Allocation - Service Class			√	√
TA Morgan Stanley Global Allocation Managed Risk - Balanced - Service Class(1)			√	√
TA MSCI EAFE Index - Service Class			√	√
TA Multi-Managed Balanced - Service Class			√	√
TA PineBridge Inflation Opportunities - Service Class	√	√
TA S&P 500 Index - Service Class			√	√
TA Small Mid Cap Value - Service Class			√	√
TA T. Rowe Price Small Cap - Service Class			√	√
TA TS&W International Equity - Service Class			√	√
TA TS&W Mid Cap Value Opportunities - Service Class			√	√
TA WMC US Growth - Service Class			√	√

(1) This Subaccount invests in an underlying fund portfolio that utilizes a volatility management strategy as part of its investment objective and/or principal investment strategy. See Investment Restrictions earlier in the prospectus for information on how volatility management strategies may impact Your Policy Value in certain optional riders.

Certain Subaccounts may not be available in all states, at all times or through all financial intermediaries. We may discontinue offering any Subaccount at any time. In some cases, a Subaccount not available through a financial intermediary may be obtained by contacting us directly. For more information on the options available for electing a Subaccount, please contact your financial intermediary or our Administrative Office.

APPENDIX

Excess Interest Adjustment Examples

Surrenders, withdrawals, transfers and amounts applied to an annuity option, from a Guaranteed Period Option of the Fixed Account before the end of its guaranteed period (the number of years You specified the money would remain in the Guaranteed Period Option) may be subject to an Excess Interest Adjustment (“EIA”). If, at the time of such transactions the guaranteed interest rate set by us for the applicable period has risen since the date of the initial guarantee, the Excess Interest Adjustment will result in a lower Cash Value. However, if the guaranteed interest rate set by us for the applicable period has fallen since the date of the initial guarantee, the Excess Interest Adjustment will result in a higher Cash Value.

Excess Interest Adjustments will not reduce the Adjusted Policy Value for a Guaranteed Period Option below the premium payments and transfers to that Guaranteed Period Option, less any prior withdrawals and transfers from the Guaranteed Period Option, plus interest at the Policy's minimum guaranteed effective annual interest rate. This is referred to as the Excess Interest Adjustment floor.

The formula that will be used to determine the Excess Interest Adjustment is:

S* (G-C)* (M/12)
S	=	Is the amount (before surrender charges, premium taxes and the application of any Guaranteed Minimum Death Benefits, if any) being surrendered, withdrawn, transferred, paid upon death, or applied to an income option that is subject to the Excess Interest Adjustment.
G	=	Is the guaranteed interest rate for the guaranteed period applicable to “S”;
C	=	Is the current guaranteed interest rate then being offered on new premium payments for the next longer option period than “M”. If this Policy form or such an option period is no longer offered, “C” will be the U.S. Treasury rate for the next longer maturity (in whole years) than “M” on the 25th day of the previous calendar month; and
M	=	Number of months remaining in the current option period for “S”, rounded up to the next higher whole number of months.
*	=	Multiplication

The following examples are for illustrative purposes only and are calculated using hypothetical values. Your experience will vary based on circumstances at the time of withdrawal. In the following examples ^ denotes exponentiation. Please note the exponentiation represents the compounding of the interest rate.

Excess Interest Adjustment Examples — (Continued)

Example 1 (Surrender, rates increase by 3%):

Assumptions:

Single premium payment = $50,000

Guarantee period = 5 Years

Guarantee rate = 5.5% per annum

Guarantee minimum interest rate = 1.5%

Surrender = Middle of Policy Year 2 (this is represented by 1.5 in this example)

Summary:
Policy Value at middle of Policy Year 2	= 50,000.00 * (1.055) ^ 1.5 = 54,181.21
Cumulative earnings	= 54,181.21 – 50,000.00 = 4,181.21
Amount free of Excess Interest Adjustment	= 4,181.21
Amount subject to Excess Interest Adjustment	= 54,181.21 – 4,181.21 = 50,000.00
Excess Interest Adjustment floor	= 50,000.00 * (1.015) ^ 1.5 = 51,129.21
Excess Interest Adjustment S* (G-C)* (M/12) where:	G = .055 C = .085 M = 42 = 50,000.00 * (.055 - .085) * (42/12)
	= -5,250.00, but Excess Interest Adjustment cannot cause the Adjusted Policy Value to fall below the Excess Interest Adjustment floor, so the adjustment is limited to 51,129.21 - 54,181.21 = -3,052.00
Adjusted Policy Value = Policy Value + Excess Interest Adjustment	= 54,181.21 + (-3,052.00) = 51,129.21

Upon surrender of the Policy, the net surrender value (Adjusted Policy Value less any surrender charge) will never be less than that required by the non-forfeiture laws of your state.

Example 2 (Surrender, rates decrease by 1%):

Assumptions:

Single premium payment = $50,000

Guarantee period = 5 Years

Guarantee rate = 5.5% per annum

Guarantee minimum interest rate = 1.5%

Surrender = Middle of Policy Year 2 (this is represented by 1.5 in this example)

Summary:
Policy Value at middle of Policy Year 2	= 50,000.00 * (1.055) ^ 1.5 = 54,181.21
Cumulative earnings	= 54,181.21 – 50,000.00 = 4,181.21
Amount free of Excess Interest Adjustment	= 4,181.21
Amount subject to Excess Interest Adjustment	= 54,181.21 – 4,181.21 = 50,000.00
Excess Interest Adjustment floor	= 50,000.00 * (1.015) ^ 1.5 = 51,129.21
Excess Interest Adjustment S* (G-C)* (M/12) where:	G = .055 C = .045 M = 42 = 50,000.00 * (.055-.045) * (42/12) = 1,750.00
Adjusted Policy Value	= 54,181.21 + 1,750.00 = 55,931.21

Upon surrender of the Policy, the net surrender value will never by less than that required by the non-forfeiture laws of your state. For the purpose of these illustrations no surrender charges are assumed.

Excess Interest Adjustment Examples — (Continued)

On a withdrawal, we will pay the policyholder the full amount of withdrawal requested (as long as the Policy Value is sufficient). Amounts withdrawn will reduce the Policy Value by an amount equal to:

R - E + SC
R	=	the requested withdrawal;
E	=	the Excess Interest Adjustment; and
SC	=	the surrender charges on EPW: where
EPW	=	the excess withdrawal amount.

Example 3 (Partial Withdrawal, rates increase by 1%):

Assumptions:

Single premium payment = $50,000

Guarantee period = 5 Years

Guarantee rate = 5.5% per annum

Partial Withdrawal = $5,000 in the middle of Policy Year 2 (this is represented by 1.5 in this example)

Summary:
Policy Value at middle of Policy Year 2	= 50,000.00 * (1.055) ^ 1.5 = 54,181.21
Cumulative earnings	= 54,181.21 – 50,000.00 = 4,181.21
Amount free of Excess Interest Adjustment	= 4,181.21
Excess Interest Adjustment S* (G-C)* (M/12) where:	S = 5,000 – 4,181.21 = 818.79 G = .055 C = .065 M = 42 = 818.79 * (.055 - .065) * (42/12) = -28.66
Remaining Policy Value at middle of Policy Year 2	= 54,181.21 - (R - E + surrender charge) = 54,181.21 - (5,000.00 - (-28.66) + 0.00) = 49,152.55

Example 4 (Partial Withdrawal, rates decrease by 1%):

Assumptions:

Single premium payment = $50,000

Guarantee period = 5 Years

Guarantee rate = 5.5% per annum

Partial Withdrawal = $5,000 in the middle of Policy Year 2 (this is represented by 1.5 in this example)

Summary:
Policy Value at middle of Policy Year 2	= 50,000.00 * (1.055) ^ 1.5 = 54,181.21
Cumulative earnings	= 54,181.21 – 50,000.00 = 4,181.21
Amount free of Excess Interest Adjustment	= 4,181.21
Excess Interest Adjustment S* (G-C)* (M/12) where:	S = 5,000 – 4,181.21 = 818.79 G = .055 C = .045 M = 42 = 818.79 * (.055 - .045)* (42/12) = 28.66
Remaining Policy Value at middle of Policy Year 2	= 54,181.21 - (R - E + surrender charge) = 54,181.21 - (5,000.00 – 28.66 + 0.00) = 49,209.87

APPENDIX

Adjusted Withdrawals - Guaranteed Minimum Death Benefit Riders

Annual Step-Up or Return of Premium (without a GLWB) Guaranteed Minimum Death Benefit (GMDB). If You make a withdrawal and either have an a) Annual Step-Up death benefit or b) Return of Premium death benefit without a GLWB rider, then Your death benefit is reduced by an amount called the adjusted withdrawal. The amount of the reduction depends on the relationship between Your Death Proceeds and Policy Value. The adjusted withdrawal is equal to the gross withdrawal multiplied by the Death Proceeds immediately prior to the withdrawal divided by the Policy Value immediately prior to the withdrawal. The formula is AW = GW * (DP/PV) where:

AW = adjusted withdrawal

GW= gross withdrawal

DP = Death Proceeds prior to the withdrawal = greatest of (PV, CV, or GMDB)

PV = Policy Value prior to the withdrawal

GMDB = guaranteed minimum death benefit prior to the withdrawal

CV = Cash Value prior to the withdrawal

The following examples describe the effect of a withdrawal on the guaranteed minimum death benefit and Policy Value, and assumes that the withdrawal is not subject to a Surrender Charge.

Example 1: Death Proceeds Greater than Policy Value

Assumptions:

Annual Step-Up GMDB

GMDB = $75,000

PV = CV = $50,000

DP = $75,000

GW = $10,000

AW = $10,000 * ($75,000/$50,000) = $15,000

Summary:
Reduction in GMDB	=$15,000
Reduction in PV/CV	=$10,000
New GMDB	=$60,000
New PV/CV	=$40,000

The GMDB is reduced more than the PV/CV because the GMDB was greater than the PV/CV immediately prior to the withdrawal.

Example 2: Death Proceeds Equal to Policy Value

Assumptions:

Return of Premium death benefit with no GLWB rider at the time of the withdrawal

GMDB = $50,000

PV = CV = $75,000

DP = $75,000

GW = $10,000

AW = $10,000 * ($75,000/$75,000) = $10,000

Summary:
Reduction in GMDB	=$10,000
Reduction in PV/CV	=$10,000
New GMDB	=$40,000
New PV/CV	=$65,000

The GMDB and PV/CV are reduced by the same amount because the PV/CV was greater than the GMDB immediately prior to the withdrawal.

Adjusted Withdrawals - Guaranteed Minimum Death Benefit Riders — (Continued)

Return of Premium (with a GLWB).

If You make a withdrawal and have a Return of Premium death benefit with a GLWB rider, then Your death benefit is reduced by an amount called the adjusted withdrawal. The amount of the reduction depends on whether the withdrawal is in excess of the Rider Withdrawal Amount (RWA), as well as the relationship between Your Death Proceeds and Policy Value. The formula is AW = lesser of (RWA or GW) + EPW * (DP-RWA) / (PV - RWA) where:

AW = adjusted withdrawal

GW = gross withdrawal

RWA = Rider Withdrawal Amount remaining prior to the withdrawal

EPW = Excess Partial Withdrawal = greater of (GW minus RWA, or zero)

DP = Death Proceeds prior to the withdrawal = greatest of (PV, CV, or GMDB)

PV = Policy Value prior to the withdrawal

GMDB = guaranteed minimum death benefit prior to the withdrawal

CV = Cash Value prior to the withdrawal

Note: The GLWB must be active at the time of the withdrawal for the above calculation to be in effect. Otherwise, the adjusted withdrawal will be calculated as previously mentioned above in the Annual Step-Up or Return of Premium (without a GLWB) Guaranteed Minimum Death Benefit (GMDB) section.

The following examples describe the effect of a withdrawal on the GMDB and Policy Value, and assumes that the withdrawal is not subject to a Surrender Charge.

Example 3: Withdrawal up to Rider Withdrawal Amount

Assumptions:

Return of Premium death benefit with GLWB rider at the time of the withdrawal

GMDB = $75,000

RWA = $4,500

PV = CV = $50,000

DP = $75,000

GW = $4,500

AW = $4,500 + ($0 * ($75,000 - $4,500) / ($50,000 - $4,500)) = $4,500

Summary:
Reduction in GMDB	=$4,500
Reduction in PV/CV	=$4,500
New GMDB	=$70,500
New PV/CV	=$45,500

The GMDB and PV/CV are reduced by the same amount because the withdrawal was not in excess of the RWA.

Example 4: Withdrawal exceeds Rider Withdrawal Amount, and Death Proceeds Greater than Policy Value

Assumptions

Return of Premium death benefit with GLWB rider at the time of the withdrawal

GMDB = $75,000

RWA = $4,500

PV = CV = $50,000

DP = $75,000

GW = $10,000

EPW = $5,500

AW = $4,500 + $5,500 * ($75,000 - $4,500) / ($50,000 - $4,500) = $13,021.98

Summary:
Reduction in GMDB	=$13,021.98
Reduction in PV/CV	=$10,000.00
New GMDB	=$61,978.02
New PV/CV	=$40,000.00

APPENDIX

Premium Based Charge

The Premium Based Charge (PBC) is determined by multiplying the premium payment by the applicable percentage based on cumulative premium payments including the current payment being made. The quarterly PBC is calculated by taking the remaining PBCs and dividing it by the number of quarters remaining in the Premium Based Charge period.

Premium Based Charge (as a percentage of premium payments)
Premium Payments	Total Charge
$0 thru $49,999.99	5.00%
$50,000.00 thru $99,999.99	4.50%
$100,000.00 thru $249,999.99	3.50%
$250,000.00 thru $499,999.99	2.50%
$500,000.00 thru $999,999.99	2.00%
$1,000,000.00 or more	1.25%

Example 1: Calculation at time of first quarterversary

On the first quarterversary
Initial premium: $240,000
Cumulative premium: $240,000
Premium Based Charge (PBC)% = 3.50%
PBC = $240,000 * 0.035 = $8,400
Quarterly PBC charged = $8,400 / 28 = $300
Remaining PBC: $8,400 - $300 = $8,100

Example 2: Calculation at time of subsequent premium payment during the second quarter and at time of the second quarterversary assuming the initial premium from Example 1

At the time of subsequent premium addition
Subsequent premium: $224,000
Cumulative premium: $224,000 + $240,000 = $464,000
Premium Based Charge (PBC)% = 2.50%
PBC for 2nd premium = $224,000 * 0.025 = $5,600

On the second quarterversary
Quarterly PBC charged = $8,100 / 27 + $5,600 / 28 = $300 + $200 = $500
Remaining PBC: ($8,100 - $300) + ($5,600 - $200) = ($7,800 + $5,400) = $13,200

Quarterly PBC in quarters 2-28 = $500
Quarterly PBC in quarter 29 = $200
Quarterly PBC thereafter = $0

Example 3: Calculation where committed premium is satisfied in the first quarter

On the first quarterversary
Committed premium: $336,000
Initial premium: $100,000
Subsequent premium during 1st quarter: $236,000
Premium Based Charge (PBC)% = 2.50% (since cumulative premium on 1st quarterversary is $336,000)
PBC = $336,000 * 0.025 = $8,400
Quarterly PBC charged = $8,400 / 28 = $300
Remaining PBC: $8,400 - $300 = $8,100

Premium Based Charge — (Continued)

Surrender Charges

The Surrender Charge is an acceleration of some or all of the remaining Premium Based Charges. For a surrender, the Surrender Charge is equal to any remaining Premium Based Charge. If a withdrawal is made in excess of the Surrender Charge Free Amount, a portion of the remaining Premium Based Charge will be deducted from the Policy Value at that time.

Example 1: Surrender with single premium

Initial premium: $240,000
Premium Based Charge (PBC)% = 3.50%
PBC = $240,000 * 0.035 = $8,400
Quarterly PBC charged = $8,400 / 28 = $300

Assume surrender occurs at the beginning of the 3rd Policy Year, after 8 quarterly PBCs have been assessed. The remaining PBC equals $8,400 - ($300 * 8) = $6,000. Therefore, upon surrender, the Surrender Charge would be equal to $6,000.

Example 2: Withdrawal with single premium

Initial premium: $240,000
Premium Based Charge (PBC)% = 3.50%
PBC = $240,000 * 0.035 = $8,400
Quarterly PBC charged = $8,400 / 28 = $300

Assume withdrawal occurs at the beginning of the 3rd Policy Year, after 8 quarterly PBCs have been assessed.

Gross withdrawal: $72,000
Surrender Charge Free Amount: 10% * $240,000 = $24,000
Excess withdrawal amount: $72,000 - $24,000 = $48,000

The Surrender Charge is equal to A * (B/C), where:

A = Remaining PBC prior to withdrawal: $8,400 - ($300 * 8) = $6,000

B = Excess withdrawal amount: $48,000

C = Remaining premium payment prior to withdrawal = $240,000

Therefore, the Surrender Charge = $6,000 * ($48,000 / $240,000) = $1,200

Quarterly PBC hereafter = remaining PBC / remaining PBC period = ($6,000 - $1,200) / 20 = $240

Example 3: Withdrawal with multiple premiums

Initial premium: $240,000
Premium Based Charge (PBC)% = 3.50%
PBC = $240,000 * 0.035 = $8,400
Quarterly PBC at end of first quarter = $8,400 / 28 = $300
Remaining PBC at end of first quarter: $8,400 - $300 = $8,100

Assume subsequent premium during 2nd quarter: $224,000
Cumulative premium: $224,000 + $240,000 = $464,000
Premium Based Charge (PBC)% = 2.50%
PBC for 2nd premium = $224,000 * 0.025 = $5,600
Quarterly PBC on 2nd premium = $5,600 / 28 = $200
Total quarterly PBC: $300 + $200 = $500

Assume withdrawal occurs at the beginning of the 3rd Policy Year, after 8 quarterly PBCs have been assessed on the initial premium, and 7 quarterly PBCs have been assessed on the subsequent premium.

Withdrawal: $308,800
Surrender Charge Free Amount: 10% * $464,000 = $46,400
Excess withdrawal amount: $308,800 - $46,400 = $262,400

Since the excess withdrawal amount entirely depletes the initial premium of $240,000, we collect a Surrender Charge on that premium equal to its remaining PBC of $6,000.

For the subsequent premium, the excess withdrawal amount = $262,400 - $240,000 = $22,400.

Premium Based Charge — (Continued)

The Surrender Charge on the subsequent premium is equal to A * (B/C), where:

A = Remaining PBC prior to withdrawal: $5,600 - ($200 * 7) = $4,200

B = Excess withdrawal amount: $22,400

C = Remaining premium payment prior to withdrawal = $224,000

Therefore, the Surrender Charge on the 2nd premium = $4,200 * ($22,400 / $224,000) = $420

Total Surrender Charge on this withdrawal = $6,000 + $420 = $6,420

Quarterly PBC hereafter = remaining PBC / remaining PBC period = ($5,600 - ($200 * 7) - $420) / 21 = $180

Example 4: Withdrawal during committed premium period where refund applies

Committed premium: $336,000
Initial Premium: $100,000

Assumed withdrawal during 1st policy month: $30,000
Surrender Charge Free Amount: 10% * $100,000 = $10,000
Excess withdrawal amount: $30,000 - $10,000 = $20,000

The Surrender Charge is equal to A * (B/C), where:

A = Remaining PBC prior to withdrawal: $100,000 * 3.50% = $3,500 (PBC% is based on cumulative premium at time of withdrawal, rather than committed premium)

B = Excess withdrawal amount: $20,000

C = Remaining premium payment prior to withdrawal = $100,000

Therefore, the Surrender Charge is = $3,500 * ($20,000 / $100,000) = $700

Assume subsequent premium 2nd policy month: $236,000
Premium Based Charge (PBC)%: 2.50% (since cumulative premium on 1st quarterversary is $336,000)
PBC: $336,000 * 0.025 = $8,400

We must re-compute the Surrender Charge on the withdrawal since the PBC% changed due to the subsequent premium.

The Surrender Charge on the subsequent premium is equal to A * (B/C), where:

A = Remaining PBC prior to withdrawal: $100,000 *2.50% = $2,500 (PBC% is based on cumulative premium as of the first quarterversary, rather than committed premium or cumulative premium at the time of the withdrawal.)

B = Excess withdrawal amount: $20,000

C = Remaining premium payment prior to withdrawal = $100,000

Therefore, the revised Surrender Charge = $2,500 * ($20,000 / $100,000) = $500

Hence, there will be a refund applied to the Policy Value on the 1st quarterversary for $200 ($700 - $500).

Total PBC: $336,000 * 0.025 = $8,400
Surrender Charge assessed: $500
Remaining PBC: $8,400 - $500 = $7,900

Quarterly PBC: $7,900 / 28 = $282.14

APPENDIX

ADDITIONAL DEATH DISTRIBUTIONSM RIDER – No Longer Available

The following example illustrates the Additional Death DistributionSM additional death benefit payable by this rider as well as the effect of a withdrawal on the Additional Death DistributionSM benefit amount. The Annuitant is less than age 71 on the rider date. Rider earnings will never be less than $0.

Example 1

Assumptions:

Policy Value on the rider date = $100,000

Premiums paid after the rider date before withdrawal = $25,000

Gross withdrawals after the rider date, none of which exceeded rider earnings = $30,000

Base Policy death benefit (assumed) on the date of death benefit calculation = $200,000

Policy Value on date of surrender = $150,000

Summary:
Rider earnings on date of withdrawal (= Policy Value on date of withdrawal, but prior to the current withdrawal – Policy Value on rider date – premiums paid after rider date + withdrawals since rider date that exceeded rider earnings = $150,000 - $100,000 - $25,000 + 0):	$25,000
Amount of withdrawal that exceeds rider earnings ($30,000 - $25,000):	$5,000
Base Policy death benefit (assumed) on the date of death benefit calculation:	$200,000
Policy Value on the date of death benefit calculations:	$175,000
Rider earnings (= Policy Value on date of death benefit calculations – Policy Value on rider date – premiums since rider date + withdrawals, including the current withdrawal, since rider date that exceeded rider earnings = $175,000 - $100,000 - $25,000 + $5,000):	$55,000
Additional death benefit amount (= additional death benefit factor * rider earnings = 40%* $55,000):	$22,000
Total death benefit paid (= base Policy death benefit plus additional death benefit amount):	$222,000

Example 2

Assumptions:

Policy Value on the rider date = $100,000

Premiums paid after the rider date before withdrawal = $0

Gross withdrawals after the rider date = $0

Base Policy death benefit (assumed) on the date of death benefit calculation = $100,000

Policy Value on the date of death benefit calculations = $75,000

Summary:
Rider earnings (= Policy Value on date of death benefit calculations – Policy Value on rider date – premiums since rider date + withdrawals, including the current withdrawal, since rider date that exceeded rider earnings = $75,000 - $100,000 - $0 + $0):	$0
Additional death benefit amount (= additional death benefit factor * rider earnings = 40%* $0):	$0
Total death benefit paid (= base Policy death benefit plus additional death benefit amount):	$100,000

APPENDIX

ADDITIONAL DEATH DISTRIBUTION+SM RIDER – no longer available

Assume the Additional Death Distribution+SM rider is added to a new Policy opened with $100,000 initial premium payment. The Annuitant is less than age 70 on the rider date. On the first and second rider anniversaries, the Policy Value is $110,000 and $95,000 respectively when the rider fees are deducted. The Annuitant adds a $25,000 premium payment in the 3rd rider year when the Policy Value is equal to $115,000 and then takes a withdrawal of $35,000 during the 4th rider year when the Policy Value is equal to $145,000. After 5 years, the Policy Value is equal to $130,000 and the Death Proceeds are equal to $145,000.

Example 1

Assumptions:

Account value on rider date (equals initial Policy Value since new Policy) = $100,000

Additional death benefit during first rider year = $0

Rider fee on first rider anniversary (= rider fee * Policy Value = 0.55% * $110,000) = $605

Additional death benefit during 2nd rider year (= sum of total rider fees paid) = $605

Summary:
Rider fee on second rider anniversary (= rider fee * Policy Value = 0.55% * $95,000)	$522.50
Additional death benefit during 3rd rider year (= sum of total rider fees paid = $605 + $522.50)	$1,127.50
Rider benefit base in 3rd rider year prior to premium addition (= account value less premiums added since rider date = $115,000 – $0)	$115,000.00
Rider benefit base in 3rd rider year after premium addition (= $140,000 - $25,000)	$115,000.00
Rider benefit base in 4th rider year prior to withdrawal (= account value less premiums added since rider date = $145,000 - $25,000)	$120,000.00
Rider benefit base in 4th rider year after withdrawal = (account value less premiums added since rider date =$110,000 - $25,000)	$85,000.00
Rider benefit base in 5th rider year (= $130,000 - $25,000)	$105,000.00
Additional death benefit = rider benefit percentage * rider benefit base = 30% * $105,000	$31,500.00
Total Death Proceeds in 5th rider year (= base Policy Death Proceeds + additional death benefit amount = $145,000 + $31,500)	$176,500.00

100

APPENDIX

Guaranteed Lifetime Withdrawal Benefit -

Transamerica Income EdgeSM rider – REBALANCING EXAMPLES

NOTE: The following demonstrates, on a purely hypothetical basis, the rebalancing mechanics of this Guaranteed Lifetime Withdrawal Benefit. The Investment Restrictions, rider fee percentages and withdrawal percentages for Your rider may vary from the percentages used below.

Rebalancing Examples

The following examples assume the initial premium allocations listed in the table below, which we assume satisfy the premium investment requirements provided in the Rate Sheet Prospectus Supplement.

Investment Option Allocations:	Initial Premium Allocations	Initial Premium Allocation Percentages
Stable Account	$20,000	20%
Select Investment Option Fund A	$13,000	13%
Select Investment Option Fund B	$13,000	13%
Select Investment Option Fund C	$4,000	4%
Total Select Investment Options	$30,000	30%
Flexible Investment Option Fund A	$14,000	14%
Flexible Investment Option Fund B	$14,000	14%
Flexible Investment Option Fund C	$22,000	22%
Total Flexible Investment Options	$50,000	50%
Total Investments	$100,000	100%

Example 1: Calculation at rider issue for the rebalance allocations:

The Stable Account portion of the Policy Value is not included in the quarterly Rebalance, therefore the rebalancing allocation percentages are calculated by multiplying the initial premium allocation percentages for the Select Investment Options and Flexible Investment Options by a ratio. The ratio is calculated by taking 100%, divided by 100% less the Stable Account premium allocation percentage. The ratio for this example would be 100% / (100% - 20%) = 1.25.

Investment Option Allocations:	Initial Allocations	Initial Allocation Percentages	Rebalancing Allocation Percentages
Stable Account	$20,000	20%	N/A
Total Select Investment Options	$30,000	30%	37.5%
Total Flexible Investment Options	$50,000	50%	62.5%
Total Investments	$100,000	100%	100%

Whole percentages are required for the rebalancing percentages and must sum up to equal 100%. To satisfy this requirement and ensure the rebalancing allocation requirement is met for each of the Investment Options, the sum of the Select Investment Options rebalancing percentage is rounded to the nearest whole percent (hereafter referred to as Select Rebalance Total) but no less than the minimum allocation for rebalance. The Select Rebalance Total is deducted from 100% to get the Total Flexible Investment Options rebalancing percentage (hereafter referred to as Flexible Rebalance Total). The Select Rebalance Total and Flexible Rebalance Total percentages are the end result which will be achieved by the quarterly Rebalance.

101

Guaranteed Lifetime Withdrawal Benefit -

Transamerica Income EdgeSM rider – REBALANCING EXAMPLES — (Continued)

Table 1:

Investment Option Allocations:	Unrounded Rebalancing Percentages	Rounded Rebalancing Percentages
Stable Account	N/A	N/A
Total Select Investment Options	37.5%	38%(1)
Total Flexible Investment Options	62.5%	62%(2)
Total Investments	100%	100%

(1)Select Rebalance Total

(2)Flexible Rebalance Total

We apply the same ratio and rounding to each individual Investment Option chosen and sum up the total Select and total Flexible Investment Options separately. The totals are compared to Select Rebalance Total and Flexible Rebalance Total to determine where any adjustments need to be made. In the example below, adjustments will need to be made to the Select Investment Options to bring the total percentage up to 38% and the Flexible Investment Options down to 62%, per the result from Table 1.

Table 2:

Investment Option Allocations:	Initial Allocations	Initial Percentages	Rebalancing Percentages
Stable Account	$20,000	20%	N/A
Select Investment Option Fund A	$13,000	13%	16%
Select Investment Option Fund B	$13,000	13%	16%
Select Investment Option Fund C	$4,000	4%	5%
Total Select Investment Options	$30,000	30%	37%
Flexible Investment Option Fund A	$14,000	14%	18%
Flexible Investment Option Fund B	$14,000	14%	18%
Flexible Investment Option Fund C	$22,000	22%	28%
Total Flexible Investment Options	$50,000	50%	64%
Total Investments	$100,000	100%	101%

To get the total Select Investment Options rebalancing percent to equal 38%, we must add 1% to one of the funds. Any adjustments will first be made equally to the fund(s) with the greatest allocation. If there are multiple funds with the greatest allocation and the adjustments cannot be divided equally, we will adjust in alphabetical order the fund(s) with the greatest allocation. In the example below, we made the adjustment to the Select Investment Option Fund A.

To get the total Flexible Investment Options rebalancing percent to equal 62%, we must subtract 2% from one or more funds. Since there is only one fund with the greatest allocation, we have made the adjustment to the Flexible Investment Option Fund C.

102

Guaranteed Lifetime Withdrawal Benefit -

Transamerica Income EdgeSM rider – REBALANCING EXAMPLES — (Continued)

Table 3:

Investment Option Allocations:	Initial Allocations	Initial Percentages	Rebalancing Percentages
Stable Account	$20,000	20%	N/A
Select Investment Option Fund A	$13,000	13%	17%
Select Investment Option Fund B	$13,000	13%	16%
Select Investment Option Fund C	$4,000	4%	5%
Total Select Investment Options	$30,000	30%	38%
Flexible Investment Option Fund A	$14,000	14%	18%
Flexible Investment Option Fund B	$14,000	14%	18%
Flexible Investment Option Fund C	$22,000	22%	26%
Total Flexible Investment Options	$50,000	50%	62%
Total Investments	$100,000	100%	100%

Example 2: Calculation for first quarter rebalance:

At the end of the first Rider Quarter, assume that the Investment Options have the following values:

Table 4:

Investment Option Allocations:	Allocation Amounts before Rebalance	Allocation Percentage of rebalancing funds Prior to Rebalance
Stable Account	$20,050	N/A
Select Investment Option Fund A	$13,090	17%
Select Investment Option Fund B	$11,550	15%
Select Investment Option Fund C	$3,850	5%
Total Select Investment Options	$28,490	37%
Flexible Investment Option Fund A	$13,090	17%
Flexible Investment Option Fund B	$14,630	19%
Flexible Investment Option Fund C	$20,790	27%
Total Flexible Investment Options	$48,510	63%
Total Investments	$97,050	100%

The result of the Rebalance back to the rebalancing percentages from Table 3 is:

103

APPENDIX

Hypothetical Adjusted withdrawals -Guaranteed

Lifetime Withdrawal Benefit Riders

This appendix explains the material features of the the Retirement Income Max®, Retirement Income Max® 2.0, Retirement Income Choice® 1.6 and Retirement Income Choice® 2.0 riders which are no longer available to elect.

When a withdrawal is taken, two parts of the Guaranteed Lifetime Withdrawal Benefit can be affected:

Withdrawal Base (“WB”); and

Rider Withdrawal Amount (“RWA”);

Withdrawal Base. Gross withdrawals in a rider year up to the rider withdrawal amount will not reduce the Withdrawal Base (“WB” ). Gross withdrawals in a rider year in excess of the Rider Withdrawal Amount (“RWA”) will reduce the Withdrawal Base by an amount equal to the greater of:

the excess gross withdrawal amount; and

a pro rata amount, the result of (A / B) * C, where:

is the excess gross withdrawal (the amount in excess of the Rider Withdrawal Amount remaining prior to the withdrawal);

is the Policy Value after the Rider Withdrawal Amount has been withdrawn, but prior to the withdrawal of the excess amount; and

is the Withdrawal Base prior to the withdrawal of the excess amount.

The following demonstrates, on a purely hypothetical basis, the effects of withdrawals under a Guaranteed Lifetime Withdrawal Benefit. The withdrawal percentages shown may not be available on all riders. Certain features may not be available on all riders. For information regarding a specific rider, please refer to that rider section in this prospectus.

Example 1 (Base):

Assumptions:

WB = $100,000

Withdrawal Percentage = 5%

RWA = 5% withdrawal would be $5,000 (5% of the current $100,000 withdrawal base)

Gross withdrawal (“GPWD” ) = $5,000

Excess withdrawal (“EWD” ) = None

Policy Value (“PV” ) = $100,000

Question: Is any portion of the withdrawal greater than the Rider Withdrawal Amount?

No. There is no excess withdrawal under the guarantee since no more than $5,000 is withdrawn.

Result. In this example, because no portion of the withdrawal was in excess of $5,000, the Withdrawal Base does not change.

Example 2 (Excess Withdrawal):

Assumptions:

WB = $100,000

Withdrawal Percentage = 5%

RWA = 5% withdrawal would be $5,000 (5% of the current $100,000 withdrawal base)

GPWD = $7,000

EWD = $2,000 ($7,000 - $5,000)

PV = $90,000

NOTE. For the Guaranteed Lifetime Withdrawal Benefit, because there was an excess withdrawal amount, the Withdrawal Base needs to be adjusted and a new lower Rider Withdrawal Amount calculated. Had the withdrawal for this example not been more than $5,000, the Withdrawal Base would remain at $100,000 and the Rider Withdrawal Amount would be $5,000. However, because an excess withdrawal has been taken, the Withdrawal Base is also reduced (this is the amount the 5% is based on).

New Withdrawal Base:

Step One. The Withdrawal Base is reduced only by the amount of the excess withdrawal or the pro rata amount, if greater.

Step Two. Calculate how much the Withdrawal Base is affected by the excess withdrawal.

The formula is (EWD / (PV - 5% withdrawal)) * WB before any adjustments

105

Hypothetical Adjusted withdrawals -Guaranteed

Lifetime Withdrawal Benefit Riders — (Continued)

($2,000 / ($90,000 - $5,000)) * $100,000 = $2,352.94

Step Three. Which is larger, the actual $2,000 excess withdrawal or the $2,352.94 pro rata amount?

$2,352.94 pro rata amount.

Step Four. What is the new Withdrawal Base upon which the Rider Withdrawal Amount is based?

$100,000 - $2,352.94 = $97,647.06

Result. The new Withdrawal Base is $97,647.06

New Rider Withdrawal Amount:

Because the Withdrawal Base was adjusted (due to the excess withdrawal) we have to calculate a new Rider Withdrawal Amount for the 5% guarantee that will be available starting on the next calendar anniversary. This calculation assumes no more activity prior to the next calendar anniversary.

Question: What is the new Rider Withdrawal Amount?

$97,647.06 (the adjusted Withdrawal Base) * 5% = $4,882.35

Result. Going forward, the maximum you can take out in a year is $4,882.35 without causing an excess withdrawal for the guarantee and further reduction of the Withdrawal Base (assuming there are no future automatic step-ups).

Example 3 (Base demonstrating growth):

Assumptions:

WB = $100,000

Withdrawal Percentage = 5%

WB in 10 years (assuming an annual growth rate percentage of 5.0%) = $100,000 * (1 + .05) ^ 10 = $162,889

RWA = 5% withdrawal beginning 10 years from the rider date would be $8,144 (5% of the then-current $162,889 Withdrawal Base)

Please Note: Withdrawals under these riders can begin prior to the 10th rider anniversary, but the WB growth will not occur during the rider years when a withdrawal is taken, and the growth stops on the 10th rider anniversary.

GPWD = $8,144

EWD = None

PV = $90,000 in 10 years

Question: Is any portion of the withdrawal greater than the Rider Withdrawal Amount?

No. There is no excess withdrawal under the guarantee if no more than $8,144 is withdrawn.

Result. In this example, because no portion of the withdrawal was in excess of $8,144, the Withdrawal Base does not change.

106

APPENDIX

Hypothetical Example of the Withdrawal Base Calculation -Retirement

Income Max® riders

The Retirement Income Max® riders can no longer be elected. The following table demonstrates, on a purely hypothetical basis, the withdrawal base calculation for the Retirement Income Max® riders using an initial premium payment of $100,000 for a Single Life Option rider at an issue age of 80. All values shown are post transaction values. The assumed withdrawal percentage in the example below is 6.30%

Rider Year	Hypothetical Policy Value	Subsequent Premium Payment	Withdrawal	Excess WB Adjustment	Growth Amount*	High MonthiversarySM Value	Withdrawal Base	Rider Withdrawal Amount
	$100,000	$	$	$	$	$100,000	$100,000	$6,300
1	$102,000	$	$	$	$	$102,000	$100,000	$6,300
1	$105,060	$	$	$	$	$105,060	$100,000	$6,300
1	$107,161	$	$	$	$	$107,161	$100,000	$6,300
1	$110,376	$	$	$	$	$110,376	$100,000	$6,300
1	$112,584	$	$	$	$	$112,584	$100,000	$6,300
1	$115,961	$	$	$	$	$115,961	$100,000	$6,300
1	$118,280	$	$	$	$	$118,280	$100,000	$6,300
1	$121,829	$	$	$	$	$121,829	$100,000	$6,300
1	$124,265	$	$	$	$	$124,265	$100,000	$6,300
1	$120,537	$	$	$	$	$124,265	$100,000	$6,300
1	$115,716	$	$	$	$	$124,265	$100,000	$6,300
1	$109,930	$	$	$	$105,000	$124,265	$124,2651	$7,829
2	$112,129	$	$	$	$	$112,129	$124,265	$7,829
2	$115,492	$	$	$	$	$115,492	$124,265	$7,829
2	$117,802	$	$	$	$	$117,802	$124,265	$7,829
2	$121,336	$	$	$	$	$121,336	$124,265	$7,829
2	$124,976	$	$	$	$	$124,976	$124,265	$7,829
2	$177,476	$50,000	$	$	$	$177,476	$174,265	$10,979
2	$175,701	$	$	$	$	$177,476	$174,265	$10,979
2	$172,187	$	$	$	$	$177,476	$174,265	$10,979
2	$167,022	$	$	$	$	$177,476	$174,265	$10,979
2	$163,681	$	$	$	$	$177,476	$174,265	$10,979
2	$166,955	$	$	$	$	$177,476	$174,265	$10,979
2	$170,294	$	$	$	$182,979	$177,476	$182,9792	$11,528
3	$166,888	$	$	$	$	$166,888	$182,979	$11,528
3	$171,895	$	$	$	$	$171,895	$182,979	$11,528
3	$173,614	$	$	$	$	$173,614	$182,979	$11,528
3	$178,822	$	$	$	$	$178,822	$182,979	$11,528
3	$175,246	$	$	$	$	$178,822	$182,979	$11,528
3	$151,741	$	$20,000	$9,676	$	$	$173,303	$
3	$154,775	$	$	$	$	$	$173,303	$
3	$159,419	$	$	$	$	$	$173,303	$
3	$161,013	$	$	$	$	$	$173,303	$
3	$165,843	$	$	$	$	$	$173,303	$
3	$174,135	$	$	$	$	$	$173,303	$

107

APPENDIX

Hypothetical Example of the Withdrawal Base Calculation -Transamerica

Income EdgeSM rider

The Transamerica Income EdgeSM Rider can no longer be elected. The following table demonstrates, on a purely hypothetical basis, the withdrawal base calculation for the Transamerica Income EdgeSM rider using an initial premium payment of $100,000 for a Single Life Option rider at an issue age of 80. All values shown are post transaction values. The assumed withdrawal percentage in the example below is 6.30%

Rider Year	Hypothetical Policy Value	Subsequent Premium Payment	Withdrawal	Excess WB Adjustment	Withdrawal Base	Rider Withdrawal Amount
	$100,000	$	$	$	$100,000	$6,000
1	$102,000	$	$	$	$100,000	$6,000
1	$105,060	$	$	$	$100,000	$6,000
1	$107,161	$	$	$	$100,000	$6,000
1	$110,376	$	$	$	$100,000	$6,000
1	$112,584	$	$	$	$100,000	$6,000
1	$115,961	$	$	$	$100,000	$6,000
1	$118,280	$	$	$	$100,000	$6,000
1	$121,829	$	$	$	$100,000	$6,000
1	$124,265	$	$	$	$100,000	$6,000
1	$120,537	$	$	$	$100,000	$6,000
1	$115,716	$	$	$	$100,000	$6,000
1	$109,930	$	$	$	$109,930	$6,596
2	$112,129	$	$	$	$109,930	$6,596
2	$115,492	$	$	$	$109,930	$6,596
2	$117,802	$	$	$	$109,930	$6,596
2	$121,336	$	$	$	$109,930	$6,596
2	$124,976	$	$	$	$109,930	$6,596
2	$177,476	$50,000	$	$	$159,930	$9,596
2	$175,701	$	$	$	$159,930	$9,596
2	$172,187	$	$	$	$159,930	$9,596
2	$167,022	$	$	$	$159,930	$9,596
2	$163,681	$	$	$	$159,930	$9,596
2	$166,955	$	$	$	$159,930	$9,596
2	$170,294	$	$	$	$170,2941	$10,218
3	$166,888	$	$	$	$170,294	$10,218
3	$171,895	$	$	$	$170,294	$10,218
3	$173,614	$	$	$	$170,294	$10,218
3	$178,822	$	$	$	$170,294	$10,218
3	$175,246	$	$	$	$170,294	$10,218
3	$151,741	$	$20,000	$10,314	$159,980	$
3	$154,775	$	$	$	$159,980	$
3	$159,419	$	$	$	$159,980	$
3	$161,013	$	$	$	$159,980	$
3	$165,843	$	$	$	$159,980	$
3	$174,135	$	$	$	$159,980	$
3	$181,101	$	$	$	$181,1011	$10,866

(1)Automatic Step-Up Applied

109

glossary of terms___________________	3
important INFORMATION you should consider about the policy_________	5
Overview of the policy______________	9
ANNUITY POLICY FEE TABLE AND EXPENSE EXAMPLES _________________________	11
Principal Risks of Investing in the Policy ____________________________	16
Business Continuity____________________	17
Transamerica life insurance company, transamerica financial life insurance company, The separate account, and portfolio companies_	17
Information About Us___________________	17
Financial Condition of the Company__________	17
The Separate Account___________________	18
The Underlying Fund Portfolios_____________	18
Other Transamerica Policies_______________	18
VOTING RIGHTS______________________	19
THE ANNUITY Policy__________________	19
PURCHASE___________________________	20
Policy Issue Requirements_________________	20
Premium Payments_____________________	20
Policy Value_________________________	21
INVESTMENT OPTIONS_________________	21
Selection of Underlying Fund Portfolios________	22
Addition, Deletion, or Substitution of Investment Options_________________________	23
The Fixed Account_____________________	24
Transfers___________________________	24
Investment Restrictions__________________	25
Market Timing and Disruptive Trading_________	26
EXPENSES____________________________	28
Transaction Expenses:___________________	28
Premium Based Charge__________________	28
Surrender Charges_____________________	28
Excess Interest Adjustment________________	29
Premium Taxes_______________________	29
Federal, State and Local Taxes______________	29
Special Service Fees_____________________	30
Transfer Fee_________________________	30
Base Contract Expenses__________________	30
Mortality and Expense Risk Fees_____________	30
Administrative Charges__________________	30
Annual Service Charge___________________	30
Fund Facilitation Fee____________________	30
Optional Benefits______________________	30
Underlying Fund Portfolio Fees and Expenses_____	30
Reduced Fees and Charges________________	31
Revenue We Receive____________________	31
general description of the policy___	32

APPENDIX
Hypothetical Adjusted withdrawals - Guaranteed Lifetime Withdrawal Benefit Riders _________________________	104
APPENDIX
Hypothetical Example of the Withdrawal Base Calculation - Retirement Income Max® riders_	106
APPENDIX
Hypothetical Example of the Withdrawal Base Calculation - Transamerica Income EdgeSM rider _________________________	108

Ownership__________________________	32
Beneficiary__________________________	32
Assignment_________________________	32
Termination for Low Value________________	33
Certain Offers________________________	33
Exchanges and/or Reinstatements____________	33
ACCESS TO YOUR MONEY_______________	33
Surrenders and Withdrawals_______________	34
Delay of Payment and Transfer______________	34
Excess Interest Adjustment________________	34
Signature Guarantee____________________	35
ANNUITY PAYMENTS (THE INCOME PHASE)_	36
Annuity Payment Options________________	36
Benefits Available Under the Policy__	38
DEATH BENEFIT_______________________	46
When We Pay A Death Benefit_____________	47
When We Do Not Pay A Death Benefit________	47
Deaths After the Annuity Commencement Date___	47
Owner Death________________________	48
Spousal Continuation___________________	48
Amount of Death Benefit_________________	48
Guaranteed Minimum Death Benefit__________	48
Adjusted Withdrawal___________________	50
Optional Benefit Riders_____________	50
ADDITIONAL FEATURES________________	61
Systematic Payout Option________________	61
Nursing Care and Terminal Condition Waiver____	61
Unemployment Waiver__________________	61
Telephone and Electronic Transactions_________	62
Dollar Cost Averaging Program_____________	62
Asset Rebalancing_____________________	63
Loans______________________________	63
TAX INFORMATION____________________	63
OTHER INFORMATION_________________	72
State Variations_______________________	72
Sending Forms and Transaction Requests in Good Order___________________________	73
Regulatory Modifications to Policy___________	73
Anti-Money Laundering (AML) and Sanctions____	73
Mixed and Shared Funding________________	74
Abandoned or Unclaimed Property___________	74
Legal Proceedings______________________	74
Distribution of the Policies________________	74
APPENDIX
PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY______________	77
APPENDIX
Designated Investment Options___	84
APPENDIX
TRANSAMERICA INCOME EDGESM Investment Options____________	87

APPENDIX
Excess Interest Adjustment Examples ______________________	89
APPENDIX
Adjusted Withdrawals - Guaranteed Minimum Death Benefit Riders_________________	92
APPENDIX
Premium Based Charge____________	95
APPENDIX
ADDITIONAL DEATH DISTRIBUTIONSM RIDER – No Longer Available____	98
APPENDIX
ADDITIONAL DEATH DISTRIBUTION+SM RIDER – no longer available____	99
APPENDIX
Guaranteed Lifetime Withdrawal Benefit - Transamerica Income Edge SM rider – REBALANCING EXAMPLES ______________________	100

Investment Option Allocations:	Allocation amounts after Rebalance	Allocation of Rebalancing after Rebalance	Allocation of Policy Value Rebalance
Stable Account	$20,050	N/A	21%
Select Investment Option Fund A	$13,090	17%	13%
Select Investment Option Fund B	$12,320	16%	13%
Select Investment Option Fund C	$3,850	5%	4%
Total Select Investment Options	$29,260	38%	30%
Flexible Investment Option Fund A	$13,860	18%	14%
Flexible Investment Option Fund B	$13,860	18%	14%
Flexible Investment Option Fund C	$20,020	26%	21%
Total Flexible Investment Options	$47,740	62%	49%
Total Investments	$97,050	100%	100%