As filed with the Securities and Exchange Commission on August 18, 2021

Registration No. 333-252121

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

PRE-EFFECTIVE AMENDMENT NO. 2

TO

FORM S-1

REGISTRATION STATEMENT

UNDER

THE SECURITIES ACT OF 1933

Transamerica Life Insurance Company

(Exact Name of Registrant as specified in its charter)

4333 Edgewood Road, NE

Cedar Rapids, IA 52499

Telephone Number: (319) 355-8511

(Address, including zip code, and telephone number, including area code, of Principal Executive Offices)

Brian Stallworth, Esq.

Transamerica Life Insurance Company

c/o Office of the General Counsel

4333 Edgewood Road, N.E.

Cedar Rapids, IA 52499-4240

Telephone Number: (319) 355-8511

(Name, Address, including zip code, and telephone number, including area code, of Agent for Service)

Approximate date of commencement of proposed sale to the public: As soon as practicable after this registration statement becomes effective.

If any of the securities being registered on this Form are to be offered on a delayed or continuous basis pursuant to Rule 415 under the Securities Act of 1933, check the following box.  ☒

If this Form is filed to register additional securities for an offering pursuant to Rule 462(b) under the Securities Act, please check the following box and list the Securities Act registration statement number of the earlier effective registration statement for the same offering.  ☐

If this Form is post-effective amendment filed pursuant to Rule 462(c) under the Securities Act, check the following box and list the Securities Act registration statement number of the earlier effective registration statement for the same offering.  ☐

If this Form is a post-effective amendment filed pursuant to Rule 462(d) under the Securities Act, check the following box and list the Securities Act registration statement number of the earlier effective registration statement for the same offering.  ☐

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company or an emerging growth company.

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 7(a)(2)(B) of the Securities Act.  ☐

Calculation of Registration Fee

The Registrant hereby amends this Registration Statement on such date or dates as may be necessary to delay its effective date until the Registrant shall file a further amendment which specifically states that this Registration Statement shall thereafter become effective in accordance with Section 8(a) of the Securities Act of 1933 or until the Registration Statement shall become effective on such date as the Securities and Exchange Commission, acting pursuant to said Section 8(a), may determine.

The information in this prospectus is not complete and may be changed. We may not sell these securities until the registration statement filed with the Securities and Exchange Commission is effective. This prospectus is not an offer to sell these securities and it is not soliciting an offer to buy these securities in any state where the offer or sale is not permitted.

[Preliminary] Prospectus Dated May 2, 2022

TRANSAMERICA STRUCTURED INDEX ADVANTAGE^SM ANNUITY

An Individual Flexible Premium Deferred Index-Linked Annuity Policy

Issued by Transamerica Life Insurance Company

Administrative Office

4333 Edgewood Road NE

Cedar Rapids, Iowa 52499-0001

(800) 525-6205

www.transamerica.com

This prospectus includes important information about the Transamerica Structured Index Advantage^SM Annuity (the “Policy”), an individual flexible premium deferred index-linked annuity policy that you can use to accumulate funds for retirement or other long-term financial planning purposes on a tax-deferred basis. When you purchase the Policy, it is a contract between you, as the owner or joint owner, and Transamerica Life Insurance Company (“us,” “we,” “our,” or the “Company”).

This prospectus describes all material terms of the Policy, including material state variations. Before you purchase the Policy, you should carefully read this prospectus and speak with your financial professional about whether the Policy is appropriate for you based on your personal circumstances and financial goals. You should also consult with a tax professional.

The Policy allows you to allocate your premium payments and earnings (if any) among the Policy’s investment options, which currently include certain index-linked investment options (“Index Account Options”) and a fixed interest option (“Fixed Account Option”).

Each Index Account Option currently has a Buffer or Floor downside feature that provides limited protection against any negative Index rate of return that may be charged to your investment for a Crediting Period. Each Index Account Option currently also has a Cap, Cap+ Accelerator, or Participation upside feature that determines the amount of positive Index rate of return that may be credited to your investment for a Crediting Period. These upside features place a limit on any positive Index rate of return that may be used to calculate the return for a Crediting Period, and, in turn, limit the amount that may be credited to your investment for a Crediting Period.

This prospectus lists the Index Account and Fixed Account Options that are currently available for investment.

Each Index Account Option includes a “Performance Lock” feature that you may choose to exercise before the end of a Crediting Period. If you choose to exercise this feature, your interim gain or loss in that Index Account Option will be “locked -in” and your investment will be transferred to a holding account and held there until the next anniversary of the Crediting Period start date, unless earlier withdrawn from the Policy. While in this holding account, your investment will no longer participate in Index performance (positive or negative) and will earn interest.

You should not buy this Policy if you are not willing to assume its investment risks. See PRODUCT RISK FACTORS below. Index-linked annuity contracts are complicated investments. You may lose money, including your principal investment and previously credited earnings under the Policy. Your losses may be significant.

You should carefully consider the risks and consequences associated with a surrender or withdrawal under the Policy. Your loss can become greater in the case of a surrender or withdrawal due to surrender charges. Your loss can also become greater due to adjustments imposed on a surrender or withdrawal taken before the end of a Crediting Period for an Index Account Option. These charges and adjustments could result in losses beyond the protection provided by the downside protection features of the Index Account Options offered under the Policy.

A six-year surrender charge period applies to the initial and any additional premium payment. Due to the surrender charges, the Policy is not appropriate for prospective purchasers who plan to take withdrawals in excess of the surrender charge-free amount (including systematic withdrawals) or surrender the Policy during the six years after the initial or any additional premium payment. In addition, a surrender or withdrawal may be subject to federal and state income taxes and a 10% federal penalty tax if made before age 59¹⁄₂.

Before the end of a Crediting Period for an Index Account Option, if you take a surrender or withdrawal, or if you exercise the Performance Lock feature, or if you annuitize the Policy, or if the Policy’s death benefit is paid, or if a fee or charge is deducted from that Index Account Option, the transaction will be based on the interim value of your investment in that Index Account Option. Interim values fluctuate daily, positively or negatively, depending on market conditions. Interim values could be unfavorable to you because they could reflect significantly less gain or more loss than would be applied at the end of a Crediting Period, which could significantly reduce the values received under the Policy. During a surrender charge period, your interim values may be lower than if your Policy were outside of the surrender charge period (although won’t necessarily be lower, depending on market conditions), even if you do not take a surrender or withdrawal.

If you have multiple ongoing Crediting Periods for Index Account Options that end at different times, any one of the transactions listed above may be based on an Interim Value for some or all of your Index Account Options. For as long as you have multiple ongoing Crediting Periods for Index Account Options, there may be no time that any such transaction can be performed without the application of at least one Interim Value.

Before the end of a Crediting Period for an Index Account Option, if you take a partial withdrawal or if a fee or charge is deducted from that Index Account Option, your investment base will be proportionately reduced. This negative adjustment could be greater than the amount withdrawn or deducted, and could significantly reduce your gains (if any) or contribute to losses at the end of the Crediting Period and will result in lower interim values for the remainder of the Crediting Period.

We expect to add and remove investment options under the Policy from time to time, and we reserve the right to only offer a single Index Account Option. If you are not comfortable with the risk that we may not offer investment options in the future that are attractive to you based on your personal preferences, risk tolerances, or time horizon, or with the risk that we may offer only a single Index Account Option in the future, this Policy is not appropriate for you. You may surrender your Policy if there are no investment options that you wish to select, but the surrender may be subject to surrender charges, will be based on an interim value if taken before the end of a Crediting Period for an Index Account Option, may be subject to taxes (including a 10% federal penalty tax if taken before age 59¹⁄₂) and your Policy will terminate.

You should carefully consider the risks and consequences associated with the Performance Lock feature. If you exercise Performance Lock for an Index Account Option, the locked-in amount will be based on an interim value and you will not participate in Index performance (positive or negative) for as long as your investment remains in the Performance Lock holding account. If you exercise Performance Lock when the interim value of your investment is lower than the amount you invested on the Crediting Period start date, you may be locking-in a loss.

Our financial obligations under the Policy are subject to our creditworthiness and claims-paying ability.

Right to Cancel Period—If you are a new investor in the Policy, you may cancel your Policy within 10 days. In some states or circumstances, this cancellation period may be longer. Upon cancellation, you will receive the value of your Policy, plus any fees or charges deducted under the Policy on the date of cancellation, unless a different amount is required by law. If you invest in an Index Account Option when you purchase the Policy, you will be subject to risk of loss during the right to cancel period because the amount refunded upon cancellation (Policy Value) will be based on an Interim Value. Interim Values fluctuate daily, positively or negatively, and may be unfavorable to you. Surrender charges do not apply upon cancellation, but the right to cancel period takes place during the Policy’s initial surrender charge period, so your Interim Values during the right to cancel period

may be lower than if your Policy were outside of a surrender charge period. You should review this prospectus, or consult with your financial professional, for additional information about the specific cancellation terms that apply.

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

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

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, and 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. This prospectus is not intended to provide tax, accounting, or legal advice.

Prospective purchasers may obtain an application to purchase the Policy through broker-dealers that have been appointed by us as insurance agents and that have selling agreements with Transamerica Capital, Inc. (“TCI”), the principal underwriter for the Policy. TCI is not required to sell any specific number of Policies. This prospectus is not an offer to sell the securities, and it is not soliciting an offer to buy the securities, in any state where offers or sales are not permitted.

The minimum initial premium payment is $25,000.

Prospectus Date: May 2, 2022

TABLE OF CONTENTS

GLOSSARY

Account – An Index Account, the Fixed Account, the Fixed Holding Account, and the Performance Lock Account.

Administrative Office – Transamerica Life Insurance Company, Attention: Customer Care Group, 4333 Edgewood Road NE, Cedar Rapids, IA 52499, (800) 525-6205.

Allocation Account – An Index Account Option or Fixed Account Option.

Allocation Anniversary – Any twelve-month anniversary of the Crediting Period start date of an Index Account Option. For a 1-year Crediting Period, the sole Allocation Anniversary would be the last day of the Crediting Period. For a multi-year Crediting Period, each anniversary of the Crediting Period start date (including the last day of the Crediting Period) would be an Allocation Anniversary.

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

Annuity Commencement Date – The date upon which annuity payments are to commence.

Beneficiary (beneficiary) – A person designated to receive the death benefit.

Best Entry Reset Maximum – For a Best Entry Enhanced Index Account Option, a percentage representing the maximum total reduction in the Initial Index Value allowed due to one or more resets.

Best Entry Reset Minimum Value – For a Best Entry Enhanced Index Account Option, the lowest value to which the Initial Index Value can be reset. The Best Entry Reset Minimum Value equals the Index Value at the beginning of the Crediting Period multiplied by (1 plus the Best Entry Reset Maximum).

Best Entry Reset Threshold – For a Best Entry Enhanced Index Account Option, the net percentage decrease in the Index Value necessary to reset the Initial Index Value during the Observation Period, comparing the Index Value at the beginning of the Crediting Period to an Index Value on an Observation Day.

Bond Reference Portfolio Yield – A reference portfolio yield rate which is the sum of a treasury rate and an option adjusted spread from a widely utilized bond index.

Buffer – A Downside Protection Type. If you select an Index Account Option with a Buffer, your investment will incur loss at the end of the Crediting Period for negative Index performance beyond the Buffer Rate. If the negative Index performance does not go beyond the Buffer Rate, you will not incur loss as a result of that negative Index performance. For example, if you select an Index Account Option with a Buffer and a Buffer Rate of 10%, and at the end of the Crediting Period the Index Change is -5%, your Index Credit Rate would be 0% (i.e., no loss due to negative Index performance). If the Index Change were -15%, your Index Credit Rate would be -5% and you would incur loss.

Buffer Rate – A percentage used to calculate the Index Credit Rate for an Index Account Option with Buffer as its Downside Protection Type when the Index Change is negative.

Business Day – Any day when the New York Stock Exchange is open for regular trading.

Cap – A Growth Opportunity Type. If you select an Index Account Option with a Cap, you will participate in positive Index performance at the end of the Crediting Period up to the Cap Rate, but no positive Index performance beyond the Cap Rate. For instance, if you select an Index Account Option with a Cap and a Cap Rate of 10%, and at the end of the Crediting Period the Index Change is 5%, your Index Credit Rate (i.e., your Index rate of return) would be +5%. If the Index Change were 15%, your Index Credit Rate would be limited to +10%.

Cap Rate – A percentage used to calculate the Index Credit Rate for an Index Account Option with Cap, Cap+ Accelerator, Credit Advantage Cap, or Credit Advantage Cap+ Accelerator as its Growth Opportunity Type when the Index Change is positive.

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Cap+ Accelerator – A Growth Opportunity Type. If you select an Index Account Option with Cap+ Accelerator, you will participate in positive Index performance at the end of the Crediting Period up to the Cap Rate and any positive Index performance beyond the Cap+ Accelerator Rate. You will not participate in positive Index performance between the Cap Rate and the Cap+ Accelerator Rate. For instance, if you select an Index Account Option with Cap+ Accelerator, a Cap Rate of 5%, and a Cap+ Accelerator Rate of 10%, and at the end of the Crediting Period the Index Change is 12%, your Index Credit Rate would be limited to +7%.

Cap+ Accelerator Rate – A percentage used to calculate the Index Credit Rate for an Index Account Option with Cap+ Accelerator or Credit Advantage Cap+ Accelerator Rate as its Growth Opportunity Type when the Index Change is positive.

Company (we, us, our) – Transamerica Life Insurance Company.

Credit Advantage – We currently offer certain Index Account Options with Growth Opportunity Types that are designated as “Credit Advantage.” You will pay an additional fee if you select one of these Index Account Options for investment. In exchange for the additional fee, these Index Account Options provide more upside potential, based on the rates we declare for their Growth Opportunity Types, than would be provided if their Growth Opportunity Types were not designated as “Credit Advantage.”

Credit Advantage Fee – The additional fee charged when you invest in an Index Account Option with a Credit Advantage Growth Opportunity Type.

Crediting Period – The duration of an Allocation Account’s investment term, expressed in years. The Crediting Period is also the period of time during which the performance of an Index Account Option is linked to the performance of an Index.

Default Option – Currently, the Fixed Account Option with a 1-year Crediting Period.

Downside Protection Type – A feature of an Index Account Option that provides limited protection from negative Index performance.

Final Index Value – The Index Value for the final day of a Crediting Period.

Fixed Account – The fixed interest account supporting the Fixed Account Options and the Performance Lock Account.

Fixed Account Option – A fixed interest investment option under the Policy.

Fixed Holding Account – The interest-bearing account generally in which premium payments are held until allocated to an Allocation Account.

Floor – A Downside Protection Type. If you select an Index Account Option with a Floor, your investment will incur loss at the end of the Crediting Period for negative Index performance up to the Floor Rate, but your investment will not incur loss for any negative Index performance beyond the Floor Rate. For example, if you select an Index Account Option with a Floor and a Floor Rate of -20%, and at the end of the Crediting Period the Index Change is -15%, your Index Credit Rate would be -15%. If the Index Change were -25%, your Index Credit Rate would be -20%.

Floor Rate – A percentage used to calculate the Index Credit Rate for an Index Account Option with Floor as its Downside Protection Type.

GMDB Benefit Base – Under the Guaranteed Minimum Death Benefit rider, the GMDB Benefit Base equals the guaranteed minimum death benefit under the rider (including any increases for additional premium payments and proportionate reductions for withdrawals).

Good Order (good order) – The receipt by the Company, at our Administrative Office, of all information, documentation, instructions, and/or premium payment deemed necessary by the Company to issue the Policy or execute any transaction pursuant to the terms of the Policy.

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Growth Opportunity Participation Rate – A percentage used to calculate the Index Credit Rate for an Index Account Option with Participation or Credit Advantage Participation as its Growth Opportunity Type.

Growth Opportunity Type – A feature of an Index Account Option that determines how and the extent to which an Index Account Option will participate in positive Index performance.

Index – The market index or exchange-traded fund to which an Index Account Option may be linked.

Index Account / Index Account Option – An index-linked investment option under the Policy.

Index Account Option Value – The value of your investment in an Index Account Option at the end of a Crediting Period.

Index Base – The portion of the Policy Value allocated to an Index Account Option, less the sum of any adjustments for withdrawals or fees and charges deducted from the Index Account Option since inception of a Crediting Period.

Index Change – The net percentage change in the Index Value between the first day of a Crediting Period and the last day of the Crediting Period.

Index Credit – A dollar amount of gain or loss reflected in your Index Account Option Value at the end of a Crediting Period. Index Credit may be positive, negative, or equal to zero.

Index Credit Rate – A percentage gain or loss used to calculate your Index Account Option Value at the end of a Crediting Period. The Index Credit Rate may be positive, negative, or equal to zero.

Index Value – The value of an Index at the end of a day. When the Index is a market index, the Index Value at the end of a day is the closing value of the Index for that day. When the Index is an exchange-traded fund, the Index Value at the end of a day is the closing share price of the fund for that day on the fund’s primary stock exchange. The Index Value on any day that is not a Business Day is the value of the Index at the end of the next Business Day. The Company relies on the Index Values reported by a third party.

Initial Index Value – The Index Value on the first day of a Crediting Period. The Initial Index Value may be reset to a lower Index Value under a Best Entry Enhanced Index Account Option.

Interim Value – The value of an Index Account Option on any Business Day during the Crediting Period, except the first and last day of the Crediting Period, used to determine the amount available in the Index Account for withdrawals, Surrender, annuitization, and the death benefit and to pay fees and charges. If you exercise Performance Lock, the “locked-in” gain or loss will be based on an Interim Value (less any remaining Credit Advantage Fees and any other applicable charges). The Interim Value for a Business Day is calculated at the end of that Business Day.

Interim Values could reflect significantly less gain or more loss than would be applied at the end of the Crediting Period. As such, there could be significantly less money available to you for a transaction that is processed based on an Interim Value. During a surrender charge period, your Interim Values may be lower than if your Policy were outside of a surrender charge period (although won’t necessarily be lower, depending on market conditions), even if you do not take a surrender or withdrawal.

Interim Value Index Credit Rate – A percentage gain or loss used to calculate an Interim Value for an Index Account Option. The Interim Value Index Credit Rate may be positive, negative, or equal to zero.

Minimum Required Cash Value – The minimum benefits under the Policy required by applicable state law.

Negative Adjustment (negative adjustment) – A proportional reduction in your Index Base if (i) a fee or charge is deducted from an Index Account Option before the conclusion of the Crediting Period; or (ii) you take a withdrawal from an Index Account Option before the conclusion of the Crediting Period. A negative adjustment could be greater than the amount withdrawn, and could significantly reduce your gains (if any) or contribute to losses at the end of the Crediting Period (because the Index rate of return will be applied to a smaller Index Base). A negative adjustment will also result in lower Interim Values for the remainder of the Crediting Period (because the interim rate of return will be applied to a smaller Index Base).

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Observation Day – For a Best Entry Enhanced Index Account Option, a day on which we observe the Index Value during the Observation Period to determine whether to reset the Initial Index Value.

Observation Frequency – For a Best Entry Enhanced Index Account Option, the frequency of Observation Days during the Observation Period.

Observation Period – For a Best Entry Enhanced Index Account Option, the time period (in days) during which the Initial Index Value may be reset beginning on the Crediting Period start date.

Option Value – The value of a hypothetical portfolio of options used to estimate the value of your Index Credit prior to the end of the Crediting Period. The replicating portfolio of options are designated by us for each Index Account Option and are used to estimate the fair value of the risk of loss and the possibility of gain at the end of a Crediting Period, expressed in percentage terms.

Owner (you, your) – The person who may exercise all rights and privileges under the Policy, including the Owner and any joint Owner.

Participation – A Growth Opportunity Type. If you select an Index Account Option with Participation, you will participate in a percentage of positive Index performance at the end of the Crediting Period, and that percentage will be the Growth Opportunity Participation Rate. For instance, if you select an Index Account Option with Participation and a Growth Opportunity Participation Rate of 80%, and at the end of the Crediting Period the Index Change is 10%, your Index Credit Rate would be +8%.

Payee – The person to whom annuity payments will be made.

Performance Lock – A feature that may be exercised for any Index Account Option on any Business Day before the end of the Crediting Period. If you exercise the Performance Lock feature, your Interim Value as of the Performance Lock Date (less any remaining Credit Advantage Fees and any other applicable charges) will be “locked-in.” You will no longer participate in any Index performance (positive or negative) for that Index Account Option, and no Index Credit will be applied at the end of the Crediting Period for that Index Account Option.

Performance Lock Account – An interest-bearing account to which your locked-in Interim Value (less any remaining Credit Advantage Fees and any other applicable charges) will be transferred upon exercising Performance Lock for an Index Account Option. The amount held in the Performance Lock Account will be credited compound interest daily based on the annual interest rate in effect on that day, and will be reduced on a dollar for dollar basis for any fees, charges, or withdrawals deducted from the Performance Lock Account. The Performance Lock Account is part of our Fixed Account.

Performance Lock Date – If you exercise the Performance Lock feature for an Index Account Option, the date as of which your Interim Value for that Index Account Option (less any remaining Credit Advantage Fees and any other applicable charges) is locked-in.

Policy – The Transamerica Structured Index Advantage^SM Annuity.

Policy Anniversary – The anniversary of the Policy Date for each year the Policy remains in force. If a certain date does not exist in a given month, the first day of the following month will be used.

Policy Date – The date on which the Policy becomes effective.

Policy Quarter – Each three month period beginning on the Policy Date.

Policy Value – The amount that represents the value of your investment in the Accounts.

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Policy Year – The 12-month period following the Policy Date. The first Policy Year starts on the Policy Date. Each subsequent Policy Year starts on the Policy Anniversary.

Premium Payment (premium payment) – An amount paid to us by or on behalf of an Owner, as consideration for the benefits provided under the Policy.

Renewal Letter (renewal letter) – We will send existing Owners a personalized letter at least 21 days before the end of each Crediting Period (or at least 21 days before the next Allocation Anniversary if that date would have been the end of the Crediting Period of the Index Account Option for which you exercised Performance Lock). Among other information, your renewal letter will: (i) remind you of your opportunity to decide how your Policy Value should be re-invested; (ii) inform you of the Allocation Account(s) that will be available for investment, as set forth in the prospectus for the Policy at that time; (iii) provide the current upside rates for the available Allocation Account(s); and (iv) remind you to submit instructions to us at least one Business Day before the end of the Crediting Period (or the next Allocation Anniversary).

Surrender – A full withdrawal of cash value and termination of the Policy.

Withdrawal (withdrawal) – A withdrawal of cash value from the Policy that is less than a Surrender. Any withdrawal that you request includes: one-time withdrawals, automatic withdrawals under the systematic payout option, withdrawals taken to satisfy required minimum distributions under the Internal Revenue Code, withdrawals under the Nursing Care and Terminal Condition Waiver, withdrawals under the Unemployment Waiver, and advisory fee withdrawals.

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.

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PRODUCT RISK FACTORS

RISK OF LOSS

An investment in this Policy is subject to the risk of loss. You may lose money, including your principal investment and previously credited earnings. Your losses may be significant.

LIQUIDITY RISK

We designed the Policy to be a long-term investment. If you are not a long-term investor, this Policy may not be appropriate for you.

INDEX PERFORMANCE RISK

The following risks related to Index performance apply when you invest in any Index Account Option.

The Indexes are subject to a variety of investment risks, many of which are complicated and interrelated. These risks may impact capital markets generally, specific market segments, or specific issuers. The risk levels associated with the Indexes also vary. If you invest in an Index Account Option with an Index that exposes you to higher investment risks, your risk of loss may be higher depending on the Index Account Option’s downside protection.

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Among other investment risks, each Index is exposed to market, issuer, and equity risk. Market risk is the risk that an Index could perform negatively over short periods due to short-term market movements and over longer periods during more prolonged market downturns. Issuer risk is the risk that changes in the financial condition or credit rating of an issuer of securities may cause the value of the Index to decline. Equity risk is the risk that changes in the value of equity securities may be more volatile than those of other asset classes, and that equity securities may underperform in comparison to the general financial markets, a particular financial market, or other asset classes.

See INDEXES for a summary of other important investment risks to which you may be exposed when you invest in an Index Account Option that is linked to a particular Index.

WITHDRAWAL AND SURRENDER RISK

You should fully understand the risks associated with any withdrawal (including the deduction of any fees or charges) or Surrender before you purchase the Policy and before you decide to take a withdrawal or Surrender. You should consult with your financial and tax professionals before you purchase the Policy or take a withdrawal or Surrender.

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DOWNSIDE PROTECTION TYPE RISK

No Downside Protection Type always provides complete protection from loss related to negative Index performance. Any Policy Value that you invest in an Index Account Option will have the downside protection afforded by that Index Account Option’s Downside Protection Type, but that protection will be limited. You assume the risk that you will incur losses to the extent that the Downside Protection Type does not protect you from negative Index performance. Your losses could be significant.

The limits on loss under a Downside Protection Type are for the duration of a single Crediting Period. If you invest in the same Index Account Option for multiple Crediting Periods, losses over multiple Crediting Periods may be larger than the stated limit for a single Crediting Period.

In general, depending on applicable rates, an Index Account Option with relatively more downside protection based on its Downside Protection Type is likely to have relatively less upside potential based on its Growth Opportunity Type. Conversely, depending on applicable rates, an Index Account Option with relatively less downside protection based on its Downside Protection Type is likely to have more upside potential based on its Growth Opportunity Type.

For any new Index Account Option that we offer in the future, we will set the rate(s) for its Downside Protection Type in our discretion.

GROWTH OPPORTUNITY TYPE RISK

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When you invest in an Index Account Option, the upside potential of your investment is generally limited by that Index Account Option’s Growth Opportunity Type. The Growth Opportunity Type may limit the upside potential of your investment by limiting your participation in positive Index performance, in which case the Index Credit Rate used to calculate gains will be lower than the Index Change. No Growth Opportunity Type guarantees that your Policy will increase in value.

In general, depending on applicable rates, an Index Account Option with relatively more upside potential based on its Growth Opportunity Type is likely to have relatively less downside protection based on its Downside Protection Type. Conversely, depending on applicable rates, an Index Account Option with relatively less upside potential based on its Growth Opportunity Type is likely to have more downside protection based on its Downside Protection Type.

We may declare new rates for the available Index Account Options’ Growth Opportunity Types for new Crediting Periods. We set these rates in our discretion, within any guaranteed limits to which we are subject as described in this prospectus. You bear the risk that the rate(s) we declare for a new Crediting Period will not be any more or less favorable to you than any guaranteed limits to which we are subject. New rates will not apply to ongoing Crediting Periods.

RISK OF LOSS RELATED TO FEES AND CHARGES

There is a risk of loss of principal and earnings as a result of the fees and charges under the Policy, including surrender charges, other transaction charges, and periodic charges. The deduction of fees and charges, and negative adjustments to your Policy from the deduction of fees and charges, may result in you realizing losses even when the Index Account Option(s) that you selected have performed positively.

INTERIM VALUE RISK

On each Business Day between the first and last day of a Crediting Period for an Index Account Option, the value of your investment in that Index Account Option is represented by the Interim Value. The Interim Value on a given Business Day determines the amount available from that Index Account Option for withdrawals, Surrender, annuitization, the death benefit, Performance Lock and to pay fees and charges.

The Interim Value for an Index Account Option will generally change each Business Day, and the change may be positive or negative compared to the last Business Day (even when the Index has increased in value). You should understand that the Interim Value for an Index Account Option on a Business Day will not impact your investment in that Index Account Option unless one of the following occurs on that Business Day:

In any of those circumstances – including the deduction of a periodic fee or charge – the transaction will be processed based on the Interim Value for that Index Account Option on that Business Day. If you have multiple ongoing Crediting Periods for Index Account Options that end at different times, any one of the transactions listed above may be based on an Interim Value for some or all of your Index Account Options. For as long as you have multiple ongoing Crediting Periods for Index Account Options, there may be no time that any such transaction can be performed without the application of at least one Interim Value.

Interim Values for an Index Account Option generally reflect less upside potential and less downside protection than would otherwise apply at the end of the Crediting Period. As such, when a transaction is processed based on an

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Interim Value, the Interim Value could reflect less gain or more loss (perhaps significantly less gain or more loss) than would be applied at the end of the Crediting Period. This means that there could be significantly less money available under your Policy for fees and charges, withdrawals, a Surrender, annuitization, and the death benefit. The application of an Interim Value may result in a loss to an Owner even if the reference Index at the time of withdrawal or Surrender or other transaction listed above is higher than at the beginning of the Crediting Period. If you use the Performance Lock feature to lock-in an Interim Value (less any remaining Credit Advantage Fees and any other applicable charges) that is lower than the amount you invested in that Index Account Option on the Crediting Period start date, you may be locking-in a loss.

During any surrender charge period, your Interim Values may be lower than if your Policy were outside of a surrender charge period (although won’t necessarily be lower, depending on market conditions). This applies even if you do not take a surrender or withdrawal. The potentially negative impact on your Interim Value is at its greatest on the first day of a surrender charge period and lessens as the remaining number of days in the surrender charge period decreases. A six-year surrender charge period applies to the initial and any additional premium payment. If you make an additional premium payment at a time when your Policy is subject to surrender charges for a previous premium payment, the surrender charge period applicable to the most recent premium payment will be used when calculating Interim Values.

See VALUING YOUR INVESTMENT IN AN INDEX ACCOUNT OPTION – INTERIM VALUES and APPENDIX A: INTERIM VALUE CALCULATIONS AND EXAMPLES.

NEGATIVE ADJUSTMENT TO INDEX BASE RISK

On the first day of the Crediting Period, your Index Base equals the dollar amount that you allocated to that Index Account Option. Your Index Base for that Index Account Option will not change unless a fee or charge is deducted from that Index Account Option, or if you take a withdrawal from that Index Account Option (including an automatic withdrawal), before the end of the Crediting Period, in which case your Index Base will be subject to a negative adjustment at that time. Your Index Base will be reduced by a proportion equal to the reduction in your Interim Value (the Interim Value will be reduced dollar for dollar based on the amount of the withdrawal or the fee or charge deducted).

A negative adjustment to your Index Base could result in less gain (if any) or more loss at the end of a Crediting Period, perhaps significantly less gain or more loss, because the Index Credit Rate will be applied to a lower Index Base. All withdrawals taken, and fees and charges deducted, from an Index Account Option before the end of a Crediting Period will trigger a negative adjustment to your Index Base, even fees and charges that are periodically deducted from your Policy. A negative adjustment to your Index Base may be greater than the amount withdrawn or the fee or charge deducted. A negative adjustment will also result in lower Interim Values for the remainder of the Crediting Period (because the interim rate of return will be applied to a smaller Index Base).

Once your Index Base for an Index Account Option has been negatively adjusted, there is no way to increase your Index Base for the remainder of the Crediting Period, and therefore no way to reverse or offset the negative impact of a negative adjustment to your Index Base.

See VALUING YOUR INVESTMENT IN AN INDEX ACCOUNT OPTION – NEGATIVE ADJUSTMENTS TO INDEX BASE and APPENDIX B: ADDITIONAL EXAMPLES FOR INDEX ACCOUNT OPTIONS.

ALLOCATION ACCOUNT AVAILABILITY RISK

We reserve the right to add and remove Allocation Accounts as available investment options. Allocation Accounts will only be added or removed through an amendment to this prospectus. We also reserve the right to make different Allocation Accounts available for investment in connection with only new premium payments (i.e., initial or additional premium payments) as opposed to at the end of a Crediting Period. There is no guarantee that any Allocation Account that you select for investment will always be available to you in the future or available with the same current upside rates. Our only guarantee regarding the availability of Allocation Accounts is that we will offer at least one Basic Index Account Option for investment.

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If we remove an Allocation Account, it will be closed such that no new premiums, reinvestments, or transfers will be allowed into that Allocation Account. If you are currently invested in an Allocation Account and it is removed, you may remain in that Allocation Account until the end of the Crediting Period.

If you are not comfortable with the risk that we may not offer Allocation Accounts in the future that are attractive to you based on your personal preferences, risk tolerances, or time horizon, or with the risk that we may offer only a single Index Account Option in the future, this Policy is not appropriate for you. You may Surrender your Policy (i.e., take a full withdrawal) if there are no Allocations Accounts that you wish to select, but the Surrender may be subject to surrender charges, will be based on an Interim Value if taken before the end of a Crediting Period for an Index Account Option, may be subject to taxes (including a 10% federal penalty tax if taken before age 59¹⁄₂), and your Policy will terminate.

PERFORMANCE LOCK RISK

On any Business Day before the end of the Crediting Period for an Index Account Option, you may exercise the Performance Lock feature. If you exercise Performance Lock, your Interim Value for that Index Account Option (less any remaining Credit Advantage Fees and any other applicable charges) on the Performance Lock Date is “locked-in” and transferred to the Performance Lock Account, where it will remain until the next Allocation Anniversary unless earlier withdrawn. The amount held in the Performance Lock Account will be credited compound interest daily based on the annual interest rate in effect on that day, and will be reduced on a dollar for dollar basis for any fees, charges, or withdrawals deducted from the Performance Lock Account.

The Performance Lock feature is subject to the following risks:

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See VALUING YOUR INVESTMENT IN AN INDEX ACCOUNT OPTION – PERFORMANCE LOCK.

CREDIT ADVANTAGE RISK

Among the available Index Account Options, we currently offer certain Index Account Options with Growth Opportunity Types that are designated as “Credit Advantage.” You will pay an additional fee if you select one of these Index Account Options for investment. In exchange for the additional fee, these Index Account Options provide more upside potential, based on the rates we declare for their Growth Opportunity Types, than would be provided if their Growth Opportunity Types were not designated as “Credit Advantage.” There is no guarantee that the increased upside potential of a Credit Advantage Growth Opportunity Type will result in gains at least equal to the additional fee or any gains at all, or that an Index Account Option with a Credit Advantage Growth Opportunity Type will outperform an Index Account Option without a Credit Advantage Growth Opportunity Type. The additional fee will increase your losses or decrease your gains.

BEST ENTRY INITIAL INDEX VALUE RESET FEATURE RISK

Each Best Entry option includes an Initial Index Value reset feature that may increase your gains or decrease your losses, but there is no guarantee that it will actually increase your gains or decrease your losses. It is possible that the Initial Index Value will not reset because the contingencies upon which the reset depends may not occur. Under such circumstances, the reset feature will ultimately have no impact on your gains or losses. Even if a reset occurs, the Best Entry option is still subject to the same risks associated with the Cap Growth Opportunity Type and the Buffer Downside Protection Type.

See AVAILABLE ALLOCATION ACCOUNTS – ENHANCED INDEX ACCOUNT OPTIONS – Best Entry.

DEFAULT OPTION RISK

Under certain circumstances, your premium payment or Policy Value may be automatically allocated to a default Allocation Account that we refer to as the “Default Option.” Currently, the Default Option is the Fixed Account Option with a 1-year Crediting Period, with the annual interest rate that we have declared for new Crediting Periods. We reserve the right to change the Default Option in the future.

To help avoid automatic allocations to the Default Option, you should always provide us with allocation instructions in good order whenever you have an opportunity to select your investment options. You must provide us with allocation instructions in good order at least one Business Day before the end of any Crediting Period (or at least one Business Day before the next Allocation Anniversary, if you exercised Performance Lock).

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Once a premium payment or Policy Value has been allocated to the Default Option, your investment in the Default Option is generally subject to the same terms and conditions as any other investment in an Allocation Account under the Policy. For example, you may not transfer Policy Value invested in the Default Option until the end of the Crediting Period. You may withdraw amounts invested in the Default Option at any time; however, you will be subject to the risks associated with a withdrawal or Surrender.

In each circumstance where Policy Value may be automatically allocated to the Default Option, we reserve the right to designate in an amendment to this prospectus a different Allocation Account to receive that Policy Value in lieu of the Default Option. If we designate a different Allocation Account, the same risks described above would apply.

DEATH BENEFIT SELECTION RISK

The GMDB rider is designed to provide a minimum death benefit, not necessarily an enhanced death benefit. Even if you elected the GMDB rider, upon death during the accumulation phase of a person who is both the Annuitant and an Owner, if the Policy Value is greater than the guaranteed minimum death benefit under the GMDB rider, the death benefit will be the Policy Value, same as the standard death benefit. You will have paid an additional fee for an optional feature that provided no financial benefit.

Upon death during the accumulation phase of an Owner who is not also the Annuitant, there is only one death benefit. The death benefit will be the Policy’s cash value. If you elected the GMDB rider, the rider’s guaranteed minimum death benefit will not apply. You will have paid an additional fee for an optional feature that provided no financial benefit.

Upon the death during the accumulation phase of an Annuitant who is not the Owner, the Policy will continue but the GMDB rider will be terminated, regardless of whether the one-time adjustment to Policy Value is based on the GMDB rider’s death benefit. If the one-time adjustment to Policy Value is not based on the GMDB rider’s death benefit, you will have paid an additional fee for an optional feature that provided no financial benefit.

See DEATH BENEFIT for additional information.

INTEREST RATE RISK

We declare interest rates for the Fixed Holding Account and the Performance Lock Account, and any Fixed Account Option for new Crediting Periods, in our discretion. There is no guarantee that we will declare any annual interest rate that is higher than the guaranteed minimum effective annual interest rate of 0.25%.

PREMIUM PAYMENT RISK

Your ability to make additional premium payments is subject to limitations, including annual and lifetime limitations on total premium payments. We will not allow additional premium payments under a Policy after the Owner (or oldest joint Owner) attains the age of 90. We reserve the right to further limit or refuse additional

premium payments and to prohibit Owners from making additional premium payments under the Policy in the future on a non-discriminatory basis. You bear the risk that you may not always be permitted to make additional premium payments. If we exercise this right, Owners will lose the ability to increase Policy Value and the optional death benefit, if elected, through additional premium payments.

INDEX SUBSTITUTION RISK

During a Crediting Period, if a market index serving as an Index is discontinued or if the calculation of the index is substantially changed by the index provider, or if an ETF that is serving as an Index is liquidated or otherwise no longer exists or if its investment objectives, strategies, or risks substantially change, we may substitute the Index with a new Index, once we obtain all necessary regulatory approvals. We will notify you of any such substitution in writing. We will seek to notify you at least 30 days prior to substituting an Index for any Index Account Option in which you are invested. However, in the event that it is necessary to substitute on less than 30 days’ notice due to

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circumstances outside of our control, we will provide notice of the substitution as soon as practicable. If we substitute an Index, we will select a new Index that we determine in our judgment is comparable to the old Index. We may look at factors that include, but are not limited to, asset class, index composition, strategy, and index liquidity.

You will have no right to reject the substitution of an Index. The performance of the new Index may differ significantly from the performance of the old Index. If we substitute the Index for an Index Account Option in which you are invested, your investment in the Policy is subject to the same terms and conditions as any other investment in an Allocation Account under the Policy. For example, you will not be permitted to transfer Policy Value prior to the end of a Crediting Period if a substitution occurs.

If we substitute an Index during a Crediting Period, we will calculate the Index Change using the original Index up until the substitution date. After the substitution date, we will calculate the Index Change using the replacement Index, but with a revised Initial Index Value for the replacement Index. The revised Initial Index Value for the replacement Index will reflect the Index Change for the original Index from the start of the Crediting Period to the substitution date. We will use a similar process if multiple substitutions occur during a Crediting Period. The substitution of an Index will have no impact on the Index Account Option’s Crediting Period, Growth Opportunity Type, Downside Protection Type, or any other features or rates for that Index Account Option other than the Index to which the Index Account Option is linked.

RISK OF LOSS DURING CANCELLATION PERIOD

You may cancel your Policy after you purchase it, but only if you cancel it within the prescribed period, which is generally 10 days after you receive the Policy (or 30 days for replacement Policies) but could vary by state. The amount refunded will generally be the Policy Value on the date of cancellation, plus any fees or charges deducted under the Policy on the date of the cancellation. If you invest in an Index Account Option when you purchase the Policy, you will be subject to risk of loss during the right to cancel period because the amount refunded upon cancellation (Policy Value) will be based on an Interim Value. Interim Values fluctuate daily, positively or negatively. Depending on market conditions, Interim Values could be unfavorable to you because they could reflect significantly less gain or more loss than would be applied at the end of a Crediting Period. Surrender charges do not apply upon cancellation, but the right to cancel period takes place during the Policy’s initial surrender charge period, so your Interim Values during the right to cancel period may be lower than if your Policy were outside of a surrender charge period. See INTERIM VALUE RISK above.

State variations may apply to your right to cancel period. See OTHER INFORMATION – State and Other

Variations.

INVOLUNTARY TERMINATION RISK

If your Policy Value is below $2,000, and there have been no premium payments made to the Policy within the last two Policy Years, we reserve the right to terminate the Policy and pay the greater of your Policy Value or the Minimum Required Cash Value (an “Involuntary Cashout”).

If you elected the optional Guaranteed Minimum Death Benefit (GMDB) rider, we will not invoke the Involuntary Cashout provision if the GMDB rider is in-force and has a death benefit amount of $2,000 or greater. If the Involuntary Cashout provision is invoked and the Policy is terminated, we will pay the greatest of (1) the Fixed Account Option, Fixed Holding Account, and the Performance Lock Account portions of the Minimum Required Cash Value plus the Index Account portions of the Policy Value; (2) the Policy Value; or (3) the guaranteed minimum death benefit amount.

FINANCIAL STRENGTH AND CLAIMS-PAYING ABILITY

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An investment in the Policy is subject to the risks related to us, Transamerica Life Insurance Company. Any obligations (including under the Index Account Options, the Fixed Account Options, the Fixed Holding Account, and the Performance Lock Account), guarantees, and benefits under the Policy are subject to our claims-paying ability. If we experience financial distress, we may be permitted by law to delay payments to you for up to six months, and we ultimately may not be able to meet our obligations to you.

The following risks relate to the Separate Account: (i) amounts under the Policy are not held in a separate account registered under Investment Company Act of 1940; (ii) Owners do not share in the investment performance of assets held in the Separate Account; and (iii) the obligations under this Policy are independent of the investment performance of the Separate Account and are the obligations of the Company.

More information about Transamerica Life Insurance Company, including our financial strength ratings, is available by visiting www.transamerica.com or calling toll-free (800) 525-6205. We encourage you to read the information about Transamerica Life Insurance Company, including our financial statements, included in APPENDIX E – TRANSAMERICA LIFE INSURANCE COMPANY AND FINANCIAL STATEMENTS.

CYBER SECURITY AND 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 administration of the Policy. We cannot assure you 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. Also, our business operations may be adversely affected by volatile natural and man-made disasters, including (but not limited to) hurricanes, earthquakes, terrorism, civil unrest, military action, fires and explosions, pandemic diseases, and other catastrophes. Such events may impact the availability and capacity of our key personnel and may have a materially adverse effect on our administration of the Policy.

COMPANY RISKS RELATED TO THE COVID-19 PANDEMIC

The COVID-19 pandemic has resulted in operational disruptions, as well as market volatility and general economic uncertainty. To address operational disruptions in connection with the COVID-19 pandemic, we have implemented business continuity plans so we can continue to provide services to our customers, even as many of our employees and the employees of our service providers continue to work remotely. While these efforts have been successful to date, we continue to be subject to risks that could negatively impact our operations, including system failure, mail delivery delays, unavailability of critical personnel due to illness or other reasons related to the pandemic, and disruptions to service providers.

Significant market volatility and negative market returns have occurred during the COVID-19 pandemic. While we are confident in our ability to manage the financial risks related to the COVID-19 pandemic, the extent and duration of such risks cannot be predicted with certainty, and prolonged negative economic conditions could have a negative impact on our financial condition. It is possible these risks could impact our financial strength and claims-paying ability.

THE ANNUITY

This prospectus describes information you should know before you purchase the Policy.

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. Once your Policy is annuitized, your annuity switches to the income phase.

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We currently sell Policies that are “qualified” or “non-qualified” under the Internal Revenue Code. You will get no additional tax advantage from this annuity if you are investing in this annuity through a tax-advantaged retirement plan (such as a 401(k) plan or Individual Retirement Account (“IRA”)). We currently sell Policies to the following plans: Traditional IRAs, Roth IRAs, SIMPLE IRAs, SEP-IRAs, 457(f) plans (in certain circumstances) and Section 401(a) plans (including profit sharing plans, defined benefit pension plans, defined contribution pension plans, 401(k) plans, and combination defined benefit/contribution plans). If you purchase the Policy as an individual retirement annuity or as 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 programs), your Policy is a qualified Policy. If you purchase the Policy as part of any other arrangement, your Policy is a non-qualified Policy.

The Policy is a “deferred” annuity. You can use the Policy to accumulate funds 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 until the Annuity Commencement Date. Each additional premium payment must be at least $50 unless a different minimum is stated in your Policy. You are not required to make any additional premium payments.

The Policy is “index-linked” because the value of each Index Account Option is linked to the performance of an Index. If you invest in one or more Index Account Options, the amount of money you are able to accumulate under your Policy depends (at least in part) upon the performance of your Index Account Options. You could lose a significant amount of money that you allocate to the Index Account Options.

We do not guarantee that a Fixed Account Option will always be available. If a Fixed Account Option is available and you invest amounts in that Fixed Account Option for a Crediting Period, your principal is guaranteed and will earn interest at a guaranteed annual interest rate during that Crediting Period. The amount of money you are able to accumulate depends upon the total interest credited.

Do not purchase this Policy if you plan to use it 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 for resale, speculation, arbitrage, viatication, or any other type of collective investment scheme.

PURCHASE

We will not issue a Policy unless:

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Right to Cancel Period: You may cancel your Policy after you purchase it, but only if you return it within the prescribed period, which is generally 10 days after you receive the Policy (for replacements the right to cancel period is generally 30 days) but could vary by state. The refund will generally be the Policy Value on the date of cancellation (plus any fees or charges deducted under the Policy on the date of the cancellation). If you invest in an Index Account Option when you purchase the Policy, you will be subject to risk of loss during the right to cancel period because the amount refunded upon cancellation (Policy Value) will be based on an Interim Value. Interim Values fluctuate daily, positively or negatively, and may be unfavorable to you. Surrender charges do not apply upon cancellation, but the right to cancel period takes place during the Policy’s initial surrender charge period, so your Interim Values during the right to cancel period may be lower than if your Policy were outside of a surrender charge period. State law may require us to refund the greater of your Policy Value or your premium payment(s). For IRAs, we will refund your premium payment(s) if cancelled within the first seven days of the right to cancel period. We will pay the refund after we receive in good order at our Administrative Office within the applicable period Written Notice of cancellation and the returned policy. The Policy will then be deemed void.

State variations may apply to your Policy. See OTHER INFORMATION – State and Other Variations.

Additional fees will apply under the Policy if you elect the optional Guaranteed Minimum Death Benefit (GMDB) rider or an Index Account Option with a Growth Opportunity Type designated as “Credit Advantage.” The GMDB rider may not be available for all Policies, in all states, at all times, or through all financial intermediaries.

We reserve the right to reject any application.

PREMIUM PAYMENTS

You should make checks for premium payments payable to Transamerica Life Insurance Company 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.

We reserve the right to restrict or refuse any premium payment.

INITIAL PREMIUM PAYMENT

The initial premium payment for qualified and non-qualified Policies must be at least $25,000 (including anticipated premiums from exchanges, transfers, or rollovers 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:

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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 a period of time 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 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 your information is not received in good order and we are unable to complete our part of the process within 30

Business Days after the Business Day that we receive your initial premium payment and your application (or electronic order form), then we will return your initial premium payment at that time. 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. Please note, the Policy Date is not the date that the initial premium payment is allocated to the selected Allocation Account(s), because the initial premium payment will be held in the Fixed Holding Account until the next 1st, 8th, 15th, or 22nd calendar day after the Policy Date, whichever occurs first. The Policy Date is used to determine certain time periods under your Policy, such as Policy Years, Policy Quarters, 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. We will credit an additional premium payment to your Policy within two Business Days after the Business Day we receive the premium payment and required information in good order at our Administrative Office.

Before an additional premium payment is allocated to the selected Allocation Account(s), it will be held in the Fixed Holding Account until the next upcoming 1st, 8th, 15th, or 22nd calendar day after we credit the additional premium payment to your Policy, whichever occurs first.

When you allocate an additional premium payment to one or more Allocation Accounts, a new Crediting Period will begin for each Allocation Account receiving the premium payment. No portion of an additional premium payment can be applied to an ongoing Crediting Period. Please note that if you invest in the same Allocation Account at different times, you may have multiple ongoing Crediting Periods for the same Allocation Account. Under such circumstances, each ongoing Crediting Period for the same Allocation Account will be treated as a separate investment under the Policy.

After the first Policy Year, we reserve the right to require our prior approval for any cumulative premium payments in a single Policy Year in excess of the following limits:

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We may approve premium payments over the maximum limit but restrict access to certain optional benefits. If you do not obtain prior approval for premium payments in excess of the dollar amounts listed above, any prohibited premium payment will be deemed not in good order.

We will not allow additional premium payments under a Policy after the Owner (or oldest joint Owner) attains the age of 90. We reserve the right to further limit or refuse additional premium payments. We may prohibit Owners from making additional premium payments under the Policy in the future on a non- discriminatory basis. If we exercise this right, Owners will lose the ability to increase Policy Value and the optional death benefit, if elected, through additional premium payments.

MAXIMUM TOTAL PREMIUM PAYMENTS

We reserve the right to require our prior approval of any cumulative premium payments in excess of:

The maximum limit on total premium payments includes premium payments under the Policy and other policies with the same Owner or same Annuitant issued by us or an affiliate. We may approve premium payments over the maximum limit but restrict access to certain optional benefits. If you do not obtain prior approval for premium payments in excess of the dollar amounts listed above, any prohibited premium payment will be deemed not in good order.

ALLOCATION OF PREMIUM PAYMENTS

Initial Premium Payment

When you purchase the Policy, we will allocate your initial premium payment to the Allocation Account(s) you selected based on the allocation instructions in your application. The allocations in your allocation instructions must be in whole percentages and must total 100%.

After you sign your Policy application, we must receive your initial premium payment within 14 calendar days of your signature date (or 60 calendar days if the Policy is funded through an exchange, transfer, or rollover). If these conditions are not met, your Policy application will be considered not in good order. If you decide to proceed with the purchase of the Policy after we determine that your Policy application is not in good order, you will be required to provide new allocation instructions.

Even if your Policy application is in good order, there may be circumstances where we cannot allocate your initial premium payment as instructed for reasons related to the Index that are outside of our control, such as if the Index is unexpectedly discontinued on short notice. In this event, we will issue the Policy (if we haven’t done so already) and process your initial premium payment as follows:

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Currently, the Default Option is the Fixed Account Option with a 1-year Crediting Period, with the annual interest rate that we have declared for new Crediting Periods. See DEFAULT OPTION.

Additional Premium Payments

The allocation instructions in your application will initially serve as your standing allocation instructions for additional premium payments. You may change your standing allocation instructions for additional premium payments by sending written instructions to our Administrative Office, by telephone, or other electronic means acceptable to us, subject to the limitations described under OTHER INFORMATION – Telephone and Electronic Transactions. The new instructions will apply to premium payments received on or after the date we receive the change request in good order.

If you make an additional premium payment and it is accompanied by allocation instructions, we will allocate the premium payment to the Allocation Account(s) you selected based on those instructions. The allocation instructions accompanying your additional premium payment will not replace your standing allocation instructions unless you specifically instruct us otherwise.

If you make an additional premium payment and it is not accompanied by allocation instructions, we will process the additional premium payment based on your standing allocation instructions. If those standing allocation instructions are not in good order because they instruct us to allocate the premium payment (or a portion thereof) to an unavailable Allocation Account, we will process the additional premium payment as follows:

Currently, the Default Option is the Fixed Account Option with a 1-year Crediting Period, with the annual interest rate that we have declared for new Crediting Periods. See DEFAULT OPTION.

FEES AND CHARGES

There are fees and charges associated with the Policy that may reduce the return on your investment.

SURRENDER CHARGES

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During the accumulation phase, you can withdraw part (withdrawal) or all (Surrender) of your Policy’s cash value. Restrictions may apply to qualified Policies. When you take a withdrawal or Surrender, we may apply a surrender charge to compensate us for start-up expenses of the Policy relating to sales, including commissions to registered representatives and other promotional expenses.

Surrender charges, if any, apply to each premium payment, regardless of how Policy Value is allocated among the Allocation Accounts. The surrender charge decreases based on the number of years since the premium payment was made, as reflected in the table below.

You can withdraw up to 10% of your premium payments each Policy Year free of surrender charges. This amount is referred to as the “surrender charge-free amount” and is determined at the time of withdrawal or Surrender. This amount is not cumulative, so any surrender charge-free amount not used in one year does not increase the surrender charge-free amount in subsequent years. If the withdrawal or Surrender is in excess of the surrender charge-free amount, you might have to pay a surrender charge on the excess amount.

For example, assume your premium payments total $100,000 and your Policy Value is $106,000 at the beginning of the second Policy Year and you request a withdrawal of $30,000. Since that amount is more than your surrender charge-free amount ($10,000), you would pay a surrender charge of $1,600 on the remaining $20,000 (i.e., 8% x ($30,000 – $10,000) = $1,600). Likewise, assume your Policy Value is $80,000 (total premium payments total $100,000) at the beginning of the second Policy Year and you Surrender your Policy. You would pay a surrender charge of $7,200 (i.e., 8% x ($100,000 – ($100,000 x 10%)) = $7,200).

For surrender charge purposes, earnings are considered to be withdrawn first, then the oldest premium is considered to be withdrawn next. While there is no surrender charge on the withdrawal of earnings or premium payments that are no longer subject to surrender charges, such amounts count towards your surrender charge-free amount when withdrawn. This means that withdrawing such amounts will reduce (possibly to zero) your surrender charge-free amount for a Policy Year.

Keep in mind that withdrawals may be taxable and, if taken before age 59¹⁄₂, may be subject to a 10% federal penalty tax. For tax purposes, withdrawals from non-qualified Policies are considered to come from taxable earnings first

See ACCESS TO YOUR MONEY – SURRENDER CHARGE WAIVERS for information about the Policy’s surrender charge waivers. Please note that any amounts withdrawn pursuant to a surrender charge waiver will count against the surrender charge-free amount for a Policy Year.

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 by regulation or regulatory authority.

Surrender charges do not apply upon payment of the death benefit or upon annuitization.

SERVICE CHARGE

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We may deduct a service charge from your Policy on each Policy Anniversary prior to the Annuity Commencement Date and when you Surrender the Policy. Each time we deduct this charge, it will not exceed 2% (as a percentage of your Policy Value, before the deduction of any fees or charges on that date) or a maximum of $50, whichever is less, and we will waive the charge if your Policy Value, or if your total premium payments minus prior withdrawals, on that date is at least equal to the minimum amount specified in your Policy.

For example, assume your Policy Value is $100,000 on a Policy Anniversary prior to the Annuity Commencement Date. Because 2% of your Policy Value on that Policy Anniversary (i.e., $2,000) is more than the maximum service charge of $50, the service charge on that Policy Anniversary would be limited to $50.

When assessed, this charge will be allocated among all of your Allocation Accounts and the Performance Lock Account in the same proportion to how your Policy Value in those Accounts is allocated at that time and will be deducted on a dollar for dollar basis. This charge will not be deducted from the Fixed Holding Account unless all other Accounts have been exhausted of value.

GUARANTEED MINIMUM DEATH BENEFIT (GMDB) RIDER FEE

If you elect the optional GMDB rider, you will be subject to an additional fee. In general, you may elect the GMDB rider only at the time that you purchase the Policy (under limited circumstances, the GMDB rider may be re-elected after termination). The fee depends on the Annuitant’s age on the date that you sign the application for the Policy (or, under limited circumstances, at the time your re-election request is received in good order). If you are electing or re-electing the GMDB rider, only one of the fee percentages listed in the table below will apply to your rider, depending on the age of the Annuitant on the date that you sign the Policy application or at the time your re-election request is received in good order.

The fee percentage applicable to your rider will not change for the life of your rider. If you re-elect the GMDB rider, the re-elected rider will be subject to the annualized fee percentages we are offering at the time of re-election. The annualized fee percentage will not exceed 2.00%.

The fee is charged as a percentage of your GMDB Benefit Base, which equals the guaranteed minimum death benefit under the rider (including any increases for additional premium payments and proportionate reductions for withdrawals).

The additional fee will be calculated and deducted quarterly, on the same day of the month as the rider effective date. If that day does not exist for a given month, the first calendar day of the following month will be used. The quarterly fee is calculated by multiplying the GMDB Benefit Base by the GMDB rider fee percentage and dividing that amount by four. For example, assume your annualized fee percentage for the GMDB rider is 0.50%, and at the end of a quarterly period prior to the Annuity Commencement Date, your GMDB Benefit base is $100,000. On that date, your GMDB rider fee would be $125 (i.e., $100,000 x 0.50% / 4 = $125).

This fee will be deducted on a pro-rated basis (based on the number of days that have elapsed since the end of the last Policy Quarter) if the rider is terminated. However, the pro-rated charge will not be deducted upon termination due to death.

When assessed, this charge will be allocated among all of your Allocation Accounts and the Performance Lock Account in the same proportion to how your Policy Value in those Accounts is allocated at that time and will be deducted on a dollar for dollar basis. This charge will not be deducted from the Fixed Holding Account unless all other Accounts have been exhausted of value.

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See DEATH BENEFIT – GUARANTEED MINIMUM DEATH BENEFIT (GMDB) RIDER for information about how the guaranteed minimum death benefit is calculated.

CREDIT ADVANTAGE FEE

If you invest in an Index Account Option with a Growth Opportunity Type designated as “Credit Advantage,” you will pay an additional fee for the increased upside potential associated with that Index Account Option. The fee percentage is annualized, which generally means that even if two Index Account Options are subject to the same fee percentage but the lengths of their Crediting Periods differ, you will pay more if you select the Index Account Option with the longer Crediting Period.

The annualized fee percentage is the percentage of your Policy Value allocated to that Index Account Option on the first day of the Crediting Period. Currently, each available Index Account Option with a Credit Advantage Growth Opportunity Type has an annualized fee percentage of 1.25%.

The dollar amount of the Credit Advantage Fee is calculated at the beginning of the Crediting Period. The fee amount will equal the dollar amount allocated to the Index Account Option on the first day of the Crediting Period, multiplied by the Credit Advantage Fee percentage, multiplied by the length of the Crediting Period (in years). For example, assume you invest $100,000 in an Index Account Option with a Credit Advantage Growth Opportunity Type, a 6 year Crediting Period, and Credit Advantage Fee of 1.25% (annualized). Based on these assumptions, you would be subject to a total Credit Advantage Fee of $7,500 for that Crediting Period (i.e., ($100,000 x 1.25%) x 6 = $7,500). If the Crediting Period were instead only 1 year, you would be subject to a total Credit Advantage Fee of $1,250 (i.e., ($100,000 x 1.25%) x 1 = $1,250).

If you invest in an Index Account Option with a Credit Advantage Growth Opportunity Type, the Credit Advantage Fee will be charged against your investment in that Index Account Option as follows:

Remaining Credit Advantage Fee amount x (amount withdrawn / Interim Value).

Please note that the remaining Credit Advantage Fee amount and Interim Value used in the formula above are those values immediately prior to the withdrawal. The remaining Credit Advantage Fee amount at any time equals the Credit Advantage Fee amount calculated at the beginning of the Crediting Period minus the cumulative portion of the Credit Advantage Fee amount assessed at the time of any prior withdrawals during the Crediting Period.

In no event will the Credit Advantage Fee amount paid for an Index Account Option for a single Crediting Period exceed the Credit Advantage Fee amount calculated at the beginning of the Crediting Period.

If a death benefit becomes payable, the remaining Credit Advantage Fee amount, less the accrued Credit Advantage Fee amount, will be waived as of the date we receive due proof of death from any beneficiary.

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SPECIAL SERVICE FEES

We may deduct a charge for the following special services: overnight delivery, duplicate policies, 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. The fees charged for any such service will vary, but will not exceed $50 per service. We will not deduct the charge from your Policy. We will require you to pay by credit card or other accepted method when you request the service. If the service involves the issuance of a check to you, we may allow you to deduct the charge from the final check.

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.

ORDERING OF FEES AND CHARGES

At the end of the Crediting Period for an Index Account Option, fees and charges are applied after the Index Credit. Likewise, before the end of a Crediting Period for an Index Account Option, gains and losses are applied before fees and charges when calculating Interim Values. For a Fixed Account Option, the Performance Lock Account, or the Fixed Holding Account, fees and charges are applied after daily interest.

If multiple fees or charges are applied to an Account on the same day, they will be applied in the following order: (1) Credit Advantage Fee at the end of a Crediting Period; (2) GMDB rider fee; (3) Credit Advantage Fee when a withdrawal is taken before the end of a Crediting Period; (4) service charge; (5) Credit Advantage Fee when Performance Lock is exercised.

PREMIUM TAXES

A deduction is also made for premium taxes, if any, imposed on us by a state, municipality, or other government agency. We will, at our discretion, deduct the tax, currently ranging from 0% to 3.5%, from the Policy Value when you begin receiving annuity payments, you Surrender the Policy, or death proceeds are paid. We may decide to deduct the tax at the time that you make a premium payment or when due to the applicable taxing authority.

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.

POLICY VALUE AND CASH VALUE

POLICY VALUE

Prior to the Annuity Commencement Date, your Policy Value represents the value of your investment in your Accounts, which may include the Fixed Holding Account, one or more Fixed Account Options, one or more Index Account Options, and the Performance Lock Account. If you invest in an Index Account Option, your Policy Value will reflect the Interim Values of your investment between the first and last day of the Crediting Period.

On any day during the accumulation phase, your total Policy Value is equal to:

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After the Annuity Commencement Date, your Policy does not have a Policy Value.

CASH VALUE

Prior to the Annuity Commencement Date, your cash value represents the total amount that is available for withdrawal or Surrender. Your cash value is equal to the Policy Value less any surrender charges, if applicable. Your cash value may be lower than or equal to your Policy Value.

After the Annuity Commencement Date, your Policy does not have a cash value.

TYPES OF ACCOUNTS

FIXED HOLDING ACCOUNT

Before an initial or additional premium payment is allocated to one or more Allocation Accounts, it will be held in the Fixed Holding Account until the next upcoming 1st, 8th, 15th, or 22nd calendar day of any month, whichever occurs first. On such day, the premium payment (plus any accrued interest) will be allocated to the appropriate Allocation Account(s) and the Crediting Period(s) will begin on that day.

The initial premium payment will be allocated from the Fixed Holding Account to the selected Allocation Account(s) on the next 1st, 8th, 15th, or 22nd calendar day after the Policy Date. An additional premium payment will be allocated from the Fixed Holding Account to the selected Allocation Account(s) on the next 1st, 8th, 15th, or 22nd calendar day after we credit the additional premium payment to your Policy. If the Policy Date, or the date we credit an additional premium payment, is the 1st, 8th, 15th, or 22nd calendar day, it will be allocated on the next 1st, 8th, 15th, or 22nd calendar day, whichever occurs first.

Amounts held in the Fixed Holding Account are credited compound interest daily based on the annual interest rate in effect on that day. We may change the current annual interest rate for the Fixed Holding Account at any time at our discretion, subject to a guaranteed minimum effective annual interest rate of 0.25%. You bear the risk that we will not credit interest at a rate greater than the guaranteed minimum effective annual interest rate. You may obtain the current annual interest rate online at www.transamerica.com/[ ] or upon request by contacting our Administrative Office or your financial intermediary.

When your allocation instructions for an initial or additional premium payment are not in good order because they instruct us to allocate your premium payment to an Allocation Account that is no longer available for investment, your premium payment may be held in the Fixed Holding Account for a longer period of time than described above. See PREMIUM PAYMENTS – ALLOCATION OF PREMIUM PAYMENTS for additional information.

FIXED ACCOUNT OPTIONS

If you invest in a Fixed Account Option, we guarantee your principal and a fixed annual interest rate for the length of the applicable Crediting Period. We will credit compound interest daily throughout the Crediting Period based on the annual interest rate we declared for that Crediting Period.

For each available Fixed Account Option, we may declare a new annual interest rate for new Crediting Periods. We determine the annual interest rates for new Crediting Periods at our discretion, subject to a guaranteed minimum effective annual interest rate of 0.25%. You bear the risk that we will not credit interest for a new Crediting Period at a rate greater than the guaranteed minimum effective annual interest rate.

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The annual interest rate declared for an ongoing Crediting Period will not change. However, the annual interest rates we declare for the available Fixed Account Options may differ from Crediting Period to Crediting Period and may differ based on the lengths of the Crediting Periods. For example, assume you have Policy Value invested in a Fixed Account Option with an ongoing 1-year Crediting Period. If that Fixed Account Option is still available for investment and you invest additional amounts in that Fixed Account Option, you will have two separate ongoing 1- year Crediting Periods for that Fixed Account Option, and the interest rates for those Crediting Periods may differ.

The Fixed Account Options that are currently available for investment are listed under AVAILABLE ALLOCATION ACCOUNTS – Available Fixed Account Options. See SELECTING YOUR INVESTMENT OPTIONS for information about how to obtain the current annual interest rates for the available Fixed Account Options.

We do not guarantee that a Fixed Account Option will always be available for investment. We reserve the right to refuse any premium payments to be allocated to, or transferred into, the Fixed Account.

INDEX ACCOUNT OPTIONS

When you invest in an Index Account Option, your investment begins on the first day of the Crediting Period and generally ends on the last day of the Crediting Period. There are certain events that could end your investment before the last day of the Crediting Period, such as if you take a full withdrawal from that Index Account Option, Surrender the Policy, or annuitize the Policy, or if the death benefit becomes payable, or if you exercise Performance Lock, before the end of the Crediting Period.

At the end of the Crediting Period, we apply gain or loss to your Policy based on how the Index Account Option performed. The Index Account Option’s performance is linked to the performance of an Index, which will either be a market index or an exchange-traded fund. See THE INDEXES. The Index’s performance is generally measured by calculating the Index Change, which is the percentage difference between the Initial Index Value and the Final Index Value.

For example, regardless of how the Index otherwise performed between the beginning and end of the Crediting Period:

The amount of gain or loss applied to your investment at the end of the Crediting Period will depend on the Index Change and the Index Account Option’s upside and downside features:

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When you invest in an Index Account Option, the upside potential of your investment is generally limited by the Growth Opportunity Type. No Growth Opportunity Type guarantees that your investment will increase in value.

See AVAILABLE ALLOCATION ACCOUNTS – GROWTH OPPORTUNITY TYPES: CALCULATING GAIN USING THE GROWTH OPPORTUNITY TYPE for more information about the Growth Opportunity Types that are available under the Policy.

No Downside Protection Type always provides complete protection from loss related to negative Index performance. You assume the risk that you will incur losses to the extent that the Downside Protection Type does not protect you from negative Index performance. Your losses could be significant.

See AVAILABLE ALLOCATION ACCOUNTS – DOWNSIDE PROTECTION TYPES: CALCULATING LOSS USING THE DOWNSIDE PROTECTION TYPES for more information about the Downside Protection Types that are available under the Policy.

Please note that we do calculate the value of your investment in an Index Account Option each Business Day between the first and last day of the Crediting Period. However, we calculate these “Interim Values”

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differently than how we calculate gains or losses at the end of a Crediting Period. Interim values fluctuate daily, positively or negatively, depending on market conditions. Interim Values could be unfavorable to you because they could reflect significantly less gain or more loss than would be applied at the end of a Crediting Period. During a surrender charge period, your Interim Values may be lower than if your Policy were outside of a surrender charge period (although won’t necessarily be lower, depending on market conditions), even if you do not take a surrender or withdrawal. There could be significantly less money available to you for any transaction that is processed based on an Interim Value, which could significantly reduce the values received under the Policy.

For more information about how gains and losses are calculated at the end of the Crediting Period, as well as about Interim Values and the Performance Lock feature, including examples, see VALUING YOUR INVESTMENT IN AN INDEX ACCOUNT OPTION below.

The Index Account Options that are currently available for investment are listed under AVAILABLE ALLOCATION ACCOUNTS – AVAILABLE INDEX ACCOUNT OPTIONS. See also SELECTING YOUR INVESTMENT OPTIONS for information about how to obtain the current upside rates for the available Index Account Options.

PERFORMANCE LOCK ACCOUNT

The Performance Lock Account is an interest-bearing account to which your locked-in Interim Value (less any remaining Credit Advantage Fees and any other applicable charges) will be transferred upon exercising Performance Lock for an Index Account Option. The amount held in the Performance Lock Account will be credited compound interest daily based on the annual interest rate in effect on that day, and will be reduced on a dollar for dollar basis for any fees, charges, or withdrawals deducted from the Performance Lock Account, until the next Allocation Anniversary. We may change the current annual interest rate for the Performance Lock Account at any time at our discretion, subject to a guaranteed minimum effective annual interest rate of 0.25%. You bear the risk that we will not credit interest at a rate greater than the guaranteed minimum effective annual interest rate. You may obtain the current annual interest rate online at www.transamerica.com/[     ] or upon request by contacting our Administrative Office or your financial intermediary. The Performance Lock Account is part of our Fixed Account.

See VALUING YOUR INVESTMENT IN AN INDEX ACCOUNT OPTION – PERFORMANCE LOCK for information about the Performance Lock feature.

VALUING YOUR INVESTMENT IN AN INDEX ACCOUNT OPTION

INDEX ACCOUNT OPTION VALUE

The value of your investment in an Index Account Option at the end of a Crediting Period is your Index Account Option Value. Your Index Account Option Value is calculated using the following formula:

Index Account Option Value = Index Base x (1 + Index Credit Rate)

The Index Credit Rate and the Index Credit may be positive, negative, or zero.

The following is an example of how we calculate your Index Account Option Value at the end of a Crediting Period: Assume you invest $10,000 in an Index Account Option. At the beginning of the Crediting Period, your Index Base is $10,000. At the end of the Crediting Period, your Index Base is still $10,000 if there were no deductions for fees

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or charges or withdrawals before the end of the Crediting Period. At the end of the Crediting Period, we will apply the Index Credit Rate to your Index Base to calculate your Index Account Option Value.

Any fees or charges deducted at the end of the Crediting Period will be deducted on a dollar for dollar basis from your Index Account Option Value after the Index Credit is applied. Continuing the examples above, if a $50 service charge were deducted from that Index Account Option on the same day that the Index Credit was applied, the Index Account Option Value would be reduced after the Index Credit to $10,950 (i.e., $11,000 – $50) or $8,950 (i.e., $9,000 – $50), respectively. See FEES AND CHARGES.

NEGATIVE ADJUSTMENTS TO INDEX BASE

On the first day of the Crediting Period, your Index Base equals the dollar amount that you allocated to that Index Account Option. Your Index Base for that Index Account Option will not change unless a fee or charge is deducted from that Index Account Option, or if you take a withdrawal from that Index Account Option (including an automatic withdrawal), before the end of the Crediting Period, in which case your Index Base will be subject to a negative adjustment at that time. Your Index Base will be reduced by a proportion equal to the reduction in your Interim Value (the Interim Value will be reduced dollar for dollar based on the amount of the withdrawal or the fee or charge deducted). There is no way to increase your Index Base during a Crediting Period, and therefore no way to reverse or offset the negative impact of a negative adjustment to your Index Base.

A negative adjustment to your Index Base could result in less gain (if any) or more loss at the end of a Crediting Period, perhaps significantly less gain or more loss, because the Index Credit Rate will be applied to a lower Index Base. All withdrawals taken, and fees and charges deducted, from an Index Account Option before the end of a Crediting Period will trigger a negative adjustment to your Index Base, even fees and charges that are periodically deducted from your Policy. A negative adjustment to your Index Base may be greater than the amount withdrawn or the fee or charge deducted. A negative adjustment will also result in lower Interim Values for the remainder of the Crediting Period (because the interim rate of return will be applied to a smaller Index Base).

For example, assume that your Index Base on the first day of a Crediting Period for an Index Account is $10,000. Further, assume that there are no deductions as a result of fees, charges, or withdrawals from that Index Account until a given day before the end of the Crediting Period, on which day your Interim Value is $9,500 (before any deductions for fees, charges, or withdrawals) and a total of $475 in fees, charges, or withdrawals is deducted from that Index Account Option on that date. The $475 deduction would reduce your Interim Value to $9,025, representing a 5% reduction in your Interim Value. As such, your Index Base would likewise be reduced by 5% to $9,500. Please note that in this example, the negative adjustment to the Index Base (-$500) was greater than the reduction in the Interim Value (-$475).

Continuing this example to the end of the Crediting Period, assume that there are no other deductions as a result of fees, charges, or withdrawals from that Index Account Option before the end of the Crediting Period:

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See APPENDIX B: ADDITIONAL EXAMPLES FOR INDEX ACCOUNT OPTIONS for additional examples of negative adjustments.

INTERIM VALUES

We calculate the Interim Value of your investment in an Index Account Option each Business Day between the first and last day of the Crediting Period. The Interim Value on a given Business Day determines the amount available from that Index Account Option for withdrawals, Surrender, and the other transactions listed below. The Interim Value is calculated at the end of a Business Day.

The Interim Value for an Index Account Option will generally change each Business Day, and the change may be positive or negative compared to the last Business Day (even when the Index has increased in value). You should understand that the Interim Value for an Index Account Option on a Business Day will not impact your investment in that Index Account Option unless one of the following transactions occurs on that Business Day:

In any of those circumstances – including the deduction of a periodic fee or charge – the transaction will be processed based on the Interim Value for that Index Account Option on that Business Day. If you have multiple ongoing Crediting Periods for Index Account Options that end at different times, any one of the transactions listed above may be based on an Interim Value for some or all of your Index Account Options. For as long as you have multiple ongoing Crediting Periods for Index Account Options, there may be no time that any such transaction can be performed without the application of at least one Interim Value.

Interim Values for an Index Account Option generally reflect less upside potential and less downside protection than would otherwise apply at the end of the Crediting Period. As such, when a transaction is processed based on an Interim Value, the Interim Value could reflect less gain or more loss (perhaps significantly less gain or more loss) than would be applied at the end of the Crediting Period. This means that there could be significantly less money available under your Policy for fees and charges, withdrawals, a Surrender, annuitization, and the death benefit. The application of an Interim Value may result in a loss to an Owner even if the reference Index at the time of withdrawal or Surrender or other transaction listed above is higher than at the beginning of the Crediting Period. If you use the Performance Lock feature to lock-in an Interim Value (less any remaining Credit Advantage Fees and any other applicable charges) that is lower than the amount you invested in that Index Account Option on the Crediting Period start date, you may be locking-in a loss.

The Interim Value for an Index Account Option is calculated using the following formula:

Index Base x (1 + Interim Value Index Credit Rate) – applicable fees and charges

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Our process for calculating Interim Values is explained in detail in APPENDIX A: INTERIM VALUE CALCULATIONS AND EXAMPLES, including the formula we use to calculate the Interim Value Index Credit Rate.

The following examples are intended to illustrate how an Interim Value is calculated. Assume that you purchase a Policy with the standard death benefit, and on the Policy Date, you invest $10,000 in an Index Account Option with a 1-year Crediting Period and a Growth Opportunity Type that isn’t designated as Credit Advantage. Further, assume that you take no withdrawals from that Index Account Option, or exercise the Performance Lock feature, before the end of the Crediting Period.

Based on these assumptions, Examples 1 and 2 illustrate the Interim Value calculation halfway through the Crediting Period with positive and negative market scenarios, respectively. Examples 3 and 4 illustrate the Interim Value calculation close to the end of the Crediting Period with positive and negative market scenarios, respectively. In these examples, if you had elected the GMDB rider or an Index Account Option with a Credit Advantage Growth Opportunity Type, your Interim Values could be lower depending on the applicable fee percentages, the dates on which those charges are deducted, and the actions you take under the Policy.

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As previously noted, during any period of time that your Policy is subject to surrender charges, your Interim Values will be lower than if your Policy were not subject to surrender charges at that time. In comparison to the examples above, the table below shows what the Interim Value would have been in each example had your Policy not been subject to surrender charges at those times (all other assumptions being the same):