CORRESP 1 filename1.htm CORRESP

December 5, 2023

Mark Cowan

Senior Counsel\Disclosure Review and Accounting Office

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E. (Mail Stop 5-6)

Washington, D.C. 20549

 

RE:

RiverSource Life of New York Account 8 (“Registrant”)

RiverSource Life Insurance Co. of NY (“Company”)

Post-Effective Amendment No. 12 on Form N-6

File Nos. 333-227507 / 811-05213

RiverSource Variable Universal Life 6 Insurance

Dear Mr. Cowan:

On behalf of RiverSource Life Insurance Co. of NY (the “Company”), we are responding to the comments of the Securities and Exchange Commission provided to us on December 1, 2023, with regard to the Registration Statement referenced above. Along with this letter, we are filing the revised supplement, which reflects conforming edits.

Comments and responses are outlined below.

Comment: If changes in this supplement apply only to new investors, in the introductory paragraph, change “your current variable insurance product statutory and initial summary prospectus” to “the current variable insurance product statutory and initial summary prospectus.”

Response: Revised as requested.

Comment: Please clarify, under I., that the Cost of Insurance and Administrative Charges apply to policies with an application date on or after 1/13/2024 and add that all other Policy fees and charges are as stated in the Fee Table.

Response: Revised as requested.

Comment: If all changes are applicable to policies issued on or after 1/13/2024, the supplement should include only changes for policies issued on or after 1/13/2024 and all references to policies with application dates before 1/13/2024 removed. The supplement should be delivered just to new investors.

Response: Revised as requested.

 

1


Comment: Under II. Funds available under policy, all items referring to existing investors should be removed.

Response: Revised as requested.

Comment: Please clarify if all listed funds are available fund offerings for new policies on or after 1/13/24 or just additional ones. To avoid confusion and for purposes of clarity as to what funds will be available after 1/13/2024, the table below should list all funds available after 1/13/2024.

Response: The table has been revised to include all funds available for policies with applications dated on or after 1/13/2024.

Comment: Please include in the supplement any changes in the KIT or Annual Portfolio Company Expenses Minimum Maximum table, if any of the fund lineup changes affect those disclosures.

Response: The KIT and Annual Portfolio Company Expenses Minimum and Maximum Table have been revised and added to the supplement to reflect the fund lineup changes.

If you have any questions concerning responses to the comments, please contact me at (612) 678-5337.

 

Sincerely,
/s/ Nicole D. Wood
Nicole D. Wood
Assistant General Counsel and
Assistant Secretary

 

2


Supplement dated December XX, 2023 to Statutory Prospectus and initial Summary Prospectus dated April 26, 2023
Product Name
Prospectus Form #/Date
RiverSource® Variable Universal Life 6 Insurance
PRO9089_12_B01_(05/23)
ISP9089_12_B01_(05/23)
The information in this supplement updates and amends certain information contained in the current variable life insurance product statutory and initial summary prospectus (together, the “prospectus”). Please read it carefully and keep it with your variable life insurance product prospectus for future reference. Except as modified in this supplement, all other terms and information contained in the prospectus remain in effect and unchanged. The terms we use in this supplement have the same meaning as in the prospectus.
I. Effective 1/13/2024, the Cost of Insurance Charge and Administrative Charge descriptions in the “Fee Table – Periodic Charges Other than Annual Fund Expenses” are deleted and replaced with the following information, for policies with application dates on or after 1/13/2024. All other policy fees and charges are as stated in the Fee Table.
CHARGE
WHEN CHARGE IS DEDUCTED
AMOUNT DEDUCTED
Cost of Insurance Charge(a)
For policies with application
dates on or after 1/13/2024.
Monthly.
Monthly rate per $1,000 of Net Amount at Risk:
Minimum: $0.005 — Female, Standard Nontobacco,
Insurance Age 0, Duration 5.
Maximum: $57.6325 – Male, Standard Tobacco,
Insurance Age 85, Duration 28.
 
Representative Insureds: $0.0125 – Female, $500,000
Specified Amount, Super Preferred Nontobacco,
Insurance Age 40, Duration 1.
 
Administrative Charge(a)
For policies with application
dates on or after 1/13/2024.
Monthly.
Monthly Rate per $1,000 of initial Specified Amount:
Minimum: $0.098 — Female, Standard Nontobacco,
Insurance Age 0, Duration 1.
Maximum: $2.979 — Male, Standard Tobacco,
Insurance Age 85, Duration 1.
 
Representative Insured: $0.148 Female, Super
Preferred Nontobacco, Insurance Age 40, Duration 1.
 
(a) This charge varies based on individual characteristics. The charges shown in the table may not be representative of the charge you will pay. For information about the charge you would pay, contact your sales representative or RiverSource Life of NY at the address or telephone number shown on the first page of this prospectus.
II. For policies with application dates on or after 1/13/2024, Ongoing fees and Expenses in the Key Information Table – Information You Should Consider About the Policy, is deleted and replaced in its entirety with the following:
Key Information Table
1

Important Information You Should Consider About the Policy
 
FEES AND EXPENSES
Location in
Statutory
Prospectus
Ongoing Fees and
Expenses (annual
charges)
In addition to surrender charges and transaction charges, an investment in
the policy is subject to certain ongoing fees and expenses, including fees
and expenses covering the cost of insurance under the policy and the cost
of the following riders if elected as optional benefits available under the
policy: Accounting Value Increase Rider, Accidental Death Benefit Rider,
Children's Insurance Rider, Waiver of Monthly Deduction Rider, Waiver of
Premium Rider and the AdvanceSource Accelerated Benefit for CI if they
are elected as optional benefits available under the policy. Such fees and
expenses are set based on various factors such as the Insured’s Risk
Classification, Insurance Age, sex and the number of years the policy is in
force. You should review the rates, fees and charges under the Policy Data
page of your policy.
You will also bear expenses associated with the Funds offered under the
policy, as shown in the following table:
Fee Tables
Transaction Fees
Base Policy
Charges
Annual Fee
Minimum
Maximum
Underlying Fund options
(Funds fees and expenses)(1)
0.25
1.26
(1) As a percentage of Fund assets.
III. For policies with application dates on or after 1/13/2024, Total Annual Operating Expenses of the Funds in the Fee Tables section of the prospectus is deleted and replaced in its entirety with the following:
Total Annual Operating Expenses of the Funds
The next table provides the minimum and maximum total operating expenses charged by the underlying Funds(1) that you may pay periodically during the time that you own the policy. A complete list of Funds available under the policy, including their annual expenses, may be found in Appendix A: Funds Available Under the Policy.
Total Annual Fund Expenses
Minimum(%)
Maximum(%)
(expenses deducted from the Fund assets, including management fees and other expenses)
0.25
1.26
(1)
Total annual Fund operating expenses are deducted from amounts that are allocated to the Fund. They include management fees and other expenses. Other expenses may include service fees that may be used to compensate service providers, including us and our affiliates, for administrative and contract owner services provided on behalf of the Fund. The amount of these payments will vary by Fund and may be significant. See “The Variable Account and the Funds” for additional information, including potential conflicts of interest these payments may create. For a more complete description of each Fund’s fees and expenses and important disclosure regarding payments the Fund and/or its affiliates make, please review the Fund’s prospectus and SAI.
IV. Funds available under the policy.
For policies with application dates on or after 1/13/2024, the Section in the prospectus titled “Appendix A: Funds Available Under the Contract” is replaced with the following.
Appendix A: Funds Available Under the Contract
The following is a list of funds available under the contract. More information about the funds is available in the prospectuses for the funds, which may be amended from time to time and can be found online at riversource.com/insurance. You can also request this information at no cost by calling 1-800-862-7919 or by sending an email request to riversourceannuityservice@ampf.com.
The current expenses and performance information below reflects fee and expenses of the funds, but do not reflect the other fees and expenses that your contract may charge. Expenses would be higher and performance would be lower if these other charges were included. Each fund’s past performance is not necessarily an indication of future performance.
2

Investment Objective
Fund and
Adviser/Sub-Adviser
Current
Expenses
Ratio
[NET]
Average Annual Total Returns
(as of 12/31/2022)
1 Year
5 Year
10 Year
Seeks long-term growth
of capital
AB VPS Large Cap Growth Portfolio (Class A)
AllianceBernstein L.P.
0.65%
(28.51%)
11.54%
15.08%
Seeks long-term capital
appreciation.
Allspring VT Small Cap Growth Fund -
Class 1
Allspring Funds Management, LLC, adviser;
Allspring Global Investments, LLC,
sub-adviser.
0.94%
(34.30%)
7.35%
10.85%
The Portfolio seeks
investment results that
correspond (before fees
and expenses) generally
to the price and yield
performance of its
underlying index, the
Alerian Midstream
Energy Select Index (the
"Index").
ALPS | Alerian Energy Infrastructure
Portfolio: Class I
ALPS Advisors, Inc.
0.95%1
17.84%
3.77%
-
Seeks long-term capital
growth. Income is a
secondary objective.
American Century VP Mid Cap Value, Class I
American Century Investment Management,
Inc.
 
(1.19%)
6.76%
11.01%
Seeks long-term capital
growth. Income is a
secondary objective.
American Century VP Value, Class I
American Century Investment Management,
Inc.
0.73%1
0.54%
7.85%
10.59%
Seeks high total
investment return.
BlackRock Global Allocation V.I. Fund
(Class I)
BlackRock Advisors, LLC, adviser; BlackRock
(Singapore) Limited, sub-adviser.
0.73%1
(15.86%)
3.50%
5.06%
Seeks investment
results that correspond
to the total return
performance of common
stocks as represented
by the MSCI EAFE Index.
Calvert VP EAFE International Index Portfolio
- Class I
Calvert Research and Management
0.48%1
(14.58%)
1.35%
4.07%
Seeks investment
results that correspond
to the investment
performance of U.S.
common stocks, as
represented by the
NASDAQ 100 Index.
Calvert VP Nasdaq 100 Index Portfolio -
Class I
Calvert Research and Management, adviser;
Ameritas Investment Partners, Inc,
subadviser.
0.48%1
(32.64%)
11.83%
15.82%
Seeks investment
results that correspond
to the investment
performance of U.S.
common stocks, as
represented by the
Russell 2000® Index.
Calvert VP Russell 2000® Small Cap Index
Portfolio - Class I
Calvert Research and Management, adviser;
Ameritas Investment Partners, Inc,
subadviser.
0.40%1
(20.52%)
3.87%
8.57%
3

Investment Objective
Fund and
Adviser/Sub-Adviser
Current
Expenses
Ratio
[NET]
Average Annual Total Returns
(as of 12/31/2022)
1 Year
5 Year
10 Year
Seeks to achieve a
competitive total return
through an actively
managed portfolio of
stocks, bonds and
money market
instruments which offer
income and capital
growth opportunity.
Calvert VP SRI Balanced Portfolio - Class I
Calvert Research and Management
0.64%
(15.41%)
6.32%
7.57%
Seeks maximum total
investment return
through a combination
of capital growth and
current income.
Columbia Variable Portfolio - Balanced Fund
(Class 1)
Columbia Management Investment Advisers,
LLC
0.74%1
(16.65%)
5.50%
8.10%
Seeks to provide
shareholders with total
return.
Columbia Variable Portfolio - Commodity
Strategy Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.75%
19.09%
7.70%
-
Seeks total return,
consisting of long-term
capital appreciation and
current income.
Columbia Variable Portfolio - Contrarian Core
Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.68%1
(18.65%)
8.44%
12.12%
Seeks to provide
shareholders with
capital appreciation.
Columbia Variable Portfolio - Disciplined
Core Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.67%
(18.72%)
8.17%
11.98%
Seeks to provide
shareholders with a high
level of current income
and, as a secondary
objective, steady growth
of capital.
Columbia Variable Portfolio - Dividend
Opportunity Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.73%1
(1.11%)
8.10%
10.06%
Non-diversified fund that
seeks to provide
shareholders with high
total return through
current income and,
secondarily, through
capital appreciation.
Columbia Variable Portfolio - Emerging
Markets Bond Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.75%
(16.03%)
(1.63%)
0.67%
Seeks to provide
shareholders with
long-term capital growth.
Columbia Variable Portfolio - Emerging
Markets Fund (Class 1)
Columbia Management Investment Advisers,
LLC
1.09%1
(32.90%)
(3.03%)
1.55%
Seeks to provide
shareholders with high
total return through
income and growth of
capital.
Columbia Variable Portfolio - Global Strategic
Income Fund (Class 1)
Columbia Management Investment Advisers,
LLC
 
(13.49%)
(0.67%)
(1.19%)
4

Investment Objective
Fund and
Adviser/Sub-Adviser
Current
Expenses
Ratio
[NET]
Average Annual Total Returns
(as of 12/31/2022)
1 Year
5 Year
10 Year
Seeks to provide
shareholders with
maximum current
income consistent with
liquidity and stability of
principal.
Columbia Variable Portfolio - Government
Money Market Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.34%1
1.22%
0.99%
0.54%
Seeks to provide
shareholders with high
current income as its
primary objective and,
as its secondary
objective, capital
growth.
Columbia Variable Portfolio - High Yield Bond
Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.64%1
(10.54%)
2.42%
3.89%
Seeks to provide
shareholders with a high
total return through
current income and
capital appreciation.
Columbia Variable Portfolio - Income
Opportunities Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.64%1
(10.01%)
2.22%
3.63%
Seeks to provide
shareholders with a high
level of current income
while attempting to
conserve the value of
the investment for the
longest period of time.
Columbia Variable Portfolio - Intermediate
Bond Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.50%
(17.06%)
0.43%
1.39%
Seeks to provide
shareholders with
long-term capital growth.
Columbia Variable Portfolio - Large Cap
Growth Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.70%1
(31.38%)
9.21%
12.60%
Seeks to provide
shareholders with
long-term capital
appreciation.
Columbia Variable Portfolio - Large Cap Index
Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.25%
(18.34%)
9.12%
12.22%
Seeks to provide
shareholders with a
level of current income
consistent with
preservation of capital.
Columbia Variable Portfolio - Limited
Duration Credit Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.41%1
(6.08%)
1.31%
1.38%
Seeks total return,
consisting of current
income and capital
appreciation.
Columbia Variable Portfolio - Long
Government/Credit Bond Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.49%1
(27.55%)
(1.35%)
-
Seeks to provide
shareholders with
capital appreciation.
Columbia Variable Portfolio - Overseas Core
Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.79%
(14.68%)
1.38%
4.22%
Seeks to provide
shareholders with
long-term growth of
capital.
Columbia Variable Portfolio - Select Large
Cap Value Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.69%
(1.84%)
8.11%
12.11%
5

Investment Objective
Fund and
Adviser/Sub-Adviser
Current
Expenses
Ratio
[NET]
Average Annual Total Returns
(as of 12/31/2022)
1 Year
5 Year
10 Year
Seeks to provide
shareholders with
growth of capital.
Columbia Variable Portfolio - Select Mid Cap
Growth Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.82%1
(30.84%)
7.05%
10.16%
Seeks to provide
shareholders with
long-term growth of
capital.
Columbia Variable Portfolio - Select Mid Cap
Value Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.82%1
(9.44%)
8.01%
10.86%
Seeks to provide
shareholders with
long-term capital growth.
Columbia Variable Portfolio - Select Small
Cap Value Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.85%1
(14.71%)
4.65%
9.39%
Seeks to provide
shareholders with
long-term capital
appreciation.
Columbia Variable Portfolio - Seligman
Global Technology Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.96%1
(31.72%)
14.63%
18.70%
Seeks total return,
consisting of current
income and capital
appreciation.
Columbia Variable Portfolio - Strategic
Income Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.68%1
(11.37%)
1.22%
2.36%
Seeks to provide
shareholders with
current income as its
primary objective and,
as its secondary
objective, preservation
of capital.
Columbia Variable Portfolio -
U.S. Government Mortgage Fund (Class 1)
Columbia Management Investment Advisers,
LLC
0.45%
(14.14%)
(0.57%)
0.83%
Seeks to provide
shareholders with a high
level of current income.
CTIVP® - American Century Diversified Bond
Fund (Class 1)
Columbia Management Investment Advisers,
LLC, adviser; American Century Investment
Management, Inc., subadviser.
0.50%
(15.29%)
0.06%
1.22%
Non-diversified fund that
seeks to provide
shareholders with total
return that exceeds the
rate of inflation over the
long term.
CTIVP® - BlackRock Global Inflation-Protected
Securities Fund (Class 1)
Columbia Management Investment Advisers,
LLC, adviser; BlackRock Financial
Management, Inc., subadviser; BlackRock
International Limited, sub-subadviser.
0.60%1
(17.51%)
0.29%
1.38%
Seeks to provide
shareholders with
current income and
capital appreciation.
CTIVP® - CenterSquare Real Estate Fund
(Class 1)
Columbia Management Investment Advisers,
LLC, adviser; CenterSquare Investment
Management LLC, subadviser.
0.80%
(24.12%)
4.03%
4.70%
Seeks to provide
shareholders with
long-term capital growth.
CTIVP® - MFS® Value Fund (Class 1)
Columbia Management Investment Advisers,
LLC, adviser; Massachusetts Financial
Services Company, subadviser.
0.62%1
(6.10%)
7.34%
11.02%
Seeks to provide
shareholders with
long-term capital growth.
CTIVP® - Morgan Stanley Advantage Fund
(Class 1)
Columbia Management Investment Advisers,
LLC, adviser; Morgan Stanley Investment
Management Inc., subadviser.
0.70%
(41.07%)
5.40%
10.36%
6

Investment Objective
Fund and
Adviser/Sub-Adviser
Current
Expenses
Ratio
[NET]
Average Annual Total Returns
(as of 12/31/2022)
1 Year
5 Year
10 Year
Seeks to provide
shareholders with
long-term capital growth.
CTIVP® - Principal Blue Chip Growth Fund
(Class 1)
Columbia Management Investment Advisers,
LLC, adviser; Principal Global Investors, LLC,
subadviser.
0.70%
(28.01%)
7.69%
12.65%
Seeks to provide
shareholders with
long-term growth of
capital and income.
CTIVP® - T. Rowe Price Large Cap Value Fund
(Class 1)
Columbia Management Investment Advisers,
LLC, adviser; T. Rowe Price Associates, Inc.,
subadviser.
0.69%
(4.96%)
7.02%
9.19%
Seeks to provide
shareholders with total
return through current
income and capital
appreciation.
CTIVP® - TCW Core Plus Bond Fund (Class 1)
Columbia Management Investment Advisers,
LLC, adviser; TCW Investment Management
Company LLC, subadviser.
0.49%
(14.19%)
0.15%
0.95%
Seeks to provide
shareholders with
long-term growth of
capital.
CTIVP® - Victory Sycamore Established Value
Fund (Class 1)
Columbia Management Investment Advisers,
LLC, adviser; Victory Capital Management
Inc., subadviser.
0.81%
(2.75%)
9.85%
13.10%
Seeks to provide
shareholders with
long-term capital growth.
CTIVP® - Westfield Mid Cap Growth Fund
(Class 1)
Columbia Management Investment Advisers,
LLC, adviser; Westfield Capital Management
Company, L.P., subadviser.
0.82%1
(25.60%)
8.74%
10.19%
Seeks to provide total
return.
Delaware Ivy VIP Asset Strategy, Class I
Delaware Management Company
 
(14.53%)
4.57%
4.60%
Seeks long-term capital
growth.
Delaware VIP® International Series -
Standard Class
Delaware Management Company, adviser;
Macquarie Funds Management HK Ltd.,
Macquarie Investment Management Global
Limited, subadvisers.
 
(17.33%)
0.76%
4.12%
Seeks capital
appreciation.
DWS Alternative Asset Allocation VIP,
Class A2
DWS Investment Management Americas
Inc., adviser; RREEF America L.L.C.,
subadvisor.
0.83%
(7.42%)
2.83%
2.44%
Seeks high level of
current income.
Eaton Vance VT Floating-Rate Income Fund -
Institutional Class
Eaton Vance Management
 
(2.26%)
2.47%
2.87%
Seeks long-term capital
appreciation.
Fidelity® VIP Contrafund® Portfolio Initial
Class
Fidelity Management & Research Company
(the Adviser) is the fund’s manager. Fidelity
Management & Research Company (UK)
Limited, Fidelity Management & Research
Company (Hong Kong) Limited, Fidelity
Management & Research Company (Japan)
Limited, subadvisers.
0.60%
(26.31%)
8.66%
11.43%
7

Investment Objective
Fund and
Adviser/Sub-Adviser
Current
Expenses
Ratio
[NET]
Average Annual Total Returns
(as of 12/31/2022)
1 Year
5 Year
10 Year
Seeks capital
appreciation.
Fidelity® VIP Emerging Markets Portfolio
Initial Class
Fidelity Management & Research Company
(the Adviser) is the fund’s manager. Fidelity
Management & Research Company (UK)
Limited, Fidelity Management & Research
Company (Hong Kong) Limited, Fidelity
Management & Research Company (Japan)
Limited, FIL Investment Advisers, FIL
Investment Advisers (UK) Limited and FIL
Investments (Japan) Limited, subadvisers.
 
(20.17%)
1.71%
4.61%
Seeks capital
appreciation.
Fidelity® VIP Energy Portfolio Initial Class
Fidelity Management & Research Company
(the Adviser) is the fund’s manager. Fidelity
Management & Research Company (UK)
Limited, Fidelity Management & Research
Company (Hong Kong) Limited, Fidelity
Management & Research Company (Japan)
Limited, subadvisers.
 
63.18%
7.19%
4.80%
Seeks to provide capital
growth.
Fidelity® VIP Growth Opportunities Portfolio
Initial Class
Fidelity Management & Research Company
(the Adviser) is the fund’s manager. Fidelity
Management & Research Company (UK)
Limited, Fidelity Management & Research
Company (Hong Kong) Limited, Fidelity
Management & Research Company (Japan)
Limited, subadvisers.
 
(38.15%)
13.09%
15.09%
Seeks as high level of
current income as is
consistent with the
preservation of capital.
Fidelity® VIP Investment Grade Bond
Portfolio Initial Class
Fidelity Management & Research Company
(the Adviser) is the fund’s manager. Fidelity
Management & Research Company (UK)
Limited, Fidelity Management & Research
Company (Hong Kong) Limited, Fidelity
Management & Research Company (Japan)
Limited, subadvisers.
 
(12.96%)
0.64%
1.53%
Seeks long-term growth
of capital.
Fidelity® VIP Mid Cap Portfolio Initial Class
Fidelity Management & Research Company
(the Adviser) is the fund’s manager. Fidelity
Management & Research Company (UK)
Limited, Fidelity Management & Research
Company (Hong Kong) Limited, Fidelity
Management & Research Company (Japan)
Limited, subadvisers.
0.61%
(14.74%)
5.95%
9.96%
8

Investment Objective
Fund and
Adviser/Sub-Adviser
Current
Expenses
Ratio
[NET]
Average Annual Total Returns
(as of 12/31/2022)
1 Year
5 Year
10 Year
Seeks a high level of
current income and may
also seek capital
appreciation.
Fidelity® VIP Strategic Income Portfolio Initial
Class
Fidelity Management & Research Company
(the Adviser) is the fund’s manager. Fidelity
Management & Research Company (UK)
Limited, Fidelity Management & Research
Company (Hong Kong) Limited, Fidelity
Management & Research Company (Japan)
Limited, FIL Investment Advisers, FIL
Investment Advisers (UK) Limited and FIL
Investments (Japan) Limited, subadvisers.
0.67%
(11.26%)
1.35%
2.46%
Seeks to maximize
income while
maintaining prospects
for capital appreciation.
Under normal market
conditions, the fund
invests in a diversified
portfolio of equity and
debt securities.
Franklin Income VIP Fund - Class 1
Franklin Advisers, Inc.
0.46%
(5.24%)
4.56%
5.78%
Seeks long-term total
return. Under normal
market conditions, the
fund invests at least
80% of its net assets in
investments of small
capitalization
companies.
Franklin Small Cap Value VIP Fund - Class 1
Franklin Mutual Advisers, LLC
0.66%1
(9.82%)
5.74%
9.36%
Seeks total return with a
low to moderate
correlation to traditional
financial market indices.
Invesco V.I. Balanced-Risk Allocation Fund,
Series I Shares
Invesco Advisers, Inc.
0.88%1
(14.35%)
2.19%
3.54%
Seeks capital
appreciation.
Invesco V.I. Main Street Small Cap Fund®,
Series I Shares
Invesco Advisers, Inc.
0.87%
(15.83%)
7.01%
10.88%
Seeks long-term growth
of capital.
Invesco V.I. Technology Fund, Series I
Shares
Invesco Advisers, Inc.
0.98%
(39.95%)
6.31%
10.46%
Seeks long-term capital
growth, consistent with
preservation of capital
and balanced by current
income.
Janus Henderson VIT Balanced Portfolio:
Institutional Shares
Janus Henderson Investors US LLC
0.62%
(16.40%)
6.69%
8.43%
Seeks to obtain
maximum total return,
consistent with
preservation of capital.
Janus Henderson VIT Flexible Bond Portfolio:
Institutional Shares
Janus Henderson Investors US LLC
0.57%1
(13.66%)
0.50%
1.35%
Seeks high current
income and the
opportunity for capital
appreciation to produce
a high total return.
Lord Abbett Series Fund Bond Debenture
Portfolio - Class VC
Lord, Abbett & Co LLC
0.89%
(12.80%)
1.01%
3.65%
9

Investment Objective
Fund and
Adviser/Sub-Adviser
Current
Expenses
Ratio
[NET]
Average Annual Total Returns
(as of 12/31/2022)
1 Year
5 Year
10 Year
Seeks total return.
MFS® Global Real Estate Portfolio - Initial
Class
Massachusetts Financial Services Company
 
(26.94%)
3.49%
5.91%
Seeks capital
appreciation.
MFS® International Growth Portfolio - Initial
Class
Massachusetts Financial Services Company
 
(14.95%)
4.51%
6.29%
Seeks total return.
MFS® Utilities Series - Initial Class
Massachusetts Financial Services Company
0.78%1
0.76%
9.00%
8.63%
Seeks maximum total
return, consistent with
preservation of capital
and prudent investment
management.
PIMCO VIT Total Return Portfolio,
Institutional Class
Pacific Investment Management Company
LLC (PIMCO)
0.52%
(14.17%)
(0.03%)
1.07%
Seeks to provide
shareholders with
long-term capital
appreciation.
Putnam VT Global Health Care Fund -
Class IA Shares
Putnam Investment Management, LLC.
Though the investment advisor has retained
the services of both Putnam Investments
Limited (PIL) and the Putnam Advisory
Company, LLC (PAC), PIL and PAC do not
currently manage any assets of the fund.
0.76%
(4.44%)
11.66%
13.35%
Seeks capital growth.
Current income is a
secondary objective.
Putnam VT International Value Fund -
Class IA Shares
Putnam Investment Management, LLC,
investment advisor. Though the investment
advisor has retained the services of both
Putnam Investments Limited (PIL) and The
Putnam Advisory Company, LLC (PAC), PIL
and PAC do not currently manage any assets
of the fund.
 
(6.70%)
2.23%
4.45%
Seeks capital growth
and current income.
Putnam VT Large Cap Value Fund - Class IA
Shares
Putnam Investment Management, LLC,
investment advisor. Though the investment
advisor has retained the services of Putnam
Investments Limited (PIL), PIL does not
currently manage any assets.
0.57%
(2.87%)
9.53%
12.04%
Seeks to provide a high
level of total return that
is consistent with an
aggressive level of risk.
Variable Portfolio - Aggressive Portfolio
(Class 1)2
Columbia Management Investment Advisers,
LLC
0.79%
(17.99%)
4.09%
6.88%
Seeks to provide a high
level of total return that
is consistent with a
conservative level of
risk.
Variable Portfolio - Conservative Portfolio
(Class 1)2
Columbia Management Investment Advisers,
LLC
0.62%1
(15.26%)
0.61%
2.09%
Pursues total return
while seeking to
manage the Fund's
exposure to equity
market volatility.
Variable Portfolio - Managed Volatility Growth
Fund (Class 1)2,3
Columbia Management Investment Advisers,
LLC
0.77%
(19.22%)
2.04%
-
10

Investment Objective
Fund and
Adviser/Sub-Adviser
Current
Expenses
Ratio
[NET]
Average Annual Total Returns
(as of 12/31/2022)
1 Year
5 Year
10 Year
Pursues total return
while seeking to
manage the Fund's
exposure to equity
market volatility.
Variable Portfolio - Managed Volatility
Moderate Growth Fund (Class 1)2,3
Columbia Management Investment Advisers,
LLC
0.73%
(17.94%)
1.64%
4.13%
Seeks to provide a high
level of total return that
is consistent with a
moderate level of risk.
Variable Portfolio - Moderate Portfolio
(Class 1)2
Columbia Management Investment Advisers,
LLC
0.71%
(16.42%)
2.58%
4.58%
Seeks to provide a high
level of total return that
is consistent with a
moderately aggressive
level of risk.
Variable Portfolio - Moderately Aggressive
Portfolio (Class 1)2
Columbia Management Investment Advisers,
LLC
0.74%
(17.38%)
3.29%
5.71%
Seeks to provide a high
level of total return that
is consistent with a
moderately conservative
level of risk.
Variable Portfolio - Moderately Conservative
Portfolio (Class 1)2
Columbia Management Investment Advisers,
LLC
0.67%
(15.93%)
1.59%
3.32%
Seeks to provide
shareholders with a high
level of current income
while conserving the
value of the investment
for the longest period of
time.
Variable Portfolio - Partners Core Bond Fund
(Class 1)
Columbia Management Investment Advisers,
LLC, adviser; J.P. Morgan Investment
Management Inc. and Allspring Global
Investments, LLC, subadvisers.
0.47%
(13.29%)
0.12%
1.05%
Seeks to provide
shareholders with
long-term capital growth.
Variable Portfolio - Partners Core Equity Fund
(Class 1)
Columbia Management Investment Advisers,
LLC, adviser; J.P. Morgan Investment
Management Inc. and T. Rowe Price
Associates, Inc., subadvisers.
0.68%
(17.35%)
7.84%
10.80%
Seeks to provide
shareholders with
long-term growth of
capital.
Variable Portfolio - Partners International
Core Equity Fund (Class 1)
Columbia Management Investment Advisers,
LLC, adviser; Schroder Investment
Management North America Inc.,
subadviser; Schroder Investment
Management North America Limited,
sub-subadviser.
0.82%
(19.51%)
0.14%
3.03%
Seeks to provide
shareholders with
long-term capital growth.
Variable Portfolio - Partners International
Growth Fund (Class 1)
Columbia Management Investment Advisers
LLC, adviser; William Blair Investment
Management, LLC and Walter Scott &
Partners Limited, subadvisers.
0.85%1
(26.69%)
0.42%
3.85%
Seeks to provide
shareholders with
long-term capital growth.
Variable Portfolio - Partners International
Value Fund (Class 1)
Columbia Management Investment Advisers,
LLC, adviser; Pzena Investment
Management, LLC and Thompson, Siegel &
Walmsley LLC, subadvisers.
0.84%1
(11.46%)
(2.22%)
2.25%
11

Investment Objective
Fund and
Adviser/Sub-Adviser
Current
Expenses
Ratio
[NET]
Average Annual Total Returns
(as of 12/31/2022)
1 Year
5 Year
10 Year
Seeks to provide
shareholders with
long-term capital growth.
Variable Portfolio - Partners Small Cap
Growth Fund (Class 1)
Columbia Management Investment Advisers,
LLC, adviser; Scout Investments, Inc. and
Allspring Global Investments, LLC,
subadvisers.
0.85%1
(28.97%)
4.30%
7.58%
Seeks to provide
shareholders with
long-term capital
appreciation.
Variable Portfolio - Partners Small Cap Value
Fund (Class 1)
Columbia Management Investment Advisers,
LLC, adviser; Segall Bryant & Hamill, LLC
and William Blair Investment Management,
LLC, subadvisers.
0.81%1
(12.94%)
3.14%
7.01%
Pursues total return
while seeking to
manage the Fund's
exposure to equity
market volatility.
Variable Portfolio - U.S. Flexible Growth Fund
(Class 1)2,3
Columbia Management Investment Advisers,
LLC
0.68%
(18.54%)
2.79%
-
Pursues total return
while seeking to
manage the Fund's
exposure to equity
market volatility.
Variable Portfolio - U.S. Flexible Moderate
Growth Fund (Class 1)2,3
Columbia Management Investment Advisers,
LLC
0.68%
(17.36%)
2.17%
-
Seeks to maximize total
return.
Western Asset Variable Global High Yield
Bond Portfolio - Class I
Legg Mason Partners Fund Adviser, LLC;
Western Asset Management Company, LLC,
Western Asset Management Company
Limited & Western Asset Management Pte.
Ltd., sub-advisors.
0.79%
(13.72%)
0.61%
2.51%
1
This Fund and its investment adviser and/or affiliates have entered into a temporary expense reimbursement arrangement and/or fee waiver. The Fund’s annual expenses reflect temporary fee reductions. Please see the Fund’s prospectus for additional information.
2
This Fund is a fund of funds and invests substantially all of its assets in other underlying funds. Because the Fund invests in other funds, it will bear its pro rata portion of the operating expenses of those underlying funds, including management fees.
3
This Fund is managed in a way that is intended to minimize volatility of returns. See “Principal Risks of Investing in the Contract.”
THIS SUPPLEMENT SHOULD BE READ AND RETAINED FOR FUTURE REFERENCE.
SUP9089-0001_(01/24)
12