IDS LIFE OF NEW YORK FLEXIBLE PORTFOLIO ANNUITY ACCOUNT
N-4/A, 2000-07-10
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                                    SECURITIES AND EXCHANGE COMMISSION

                                          Washington, D.C. 20549

                                                 FORM N-4

                         REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933

         Pre-Effective Amendment No.        (File No. 333-91691)            [1]

         Post-Effective Amendment No.                                       [ ]

                                                  and/or

                     REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF
                     1940

                   Amendment No. 2 (File No. 811-07623) [ X ]

                           (Check appropriate box or boxes)

                      IDS LIFE OF NEW YORK VARIABLE ANNUITY ACCOUNT

            (formerly IDS Life of New York Flexible Portfolio Annuity Account)
    ----------------------------------------------------------------------------

                                        (Exact Name of Registrant)

                                  IDS Life Insurance Company of New York
          ----------------------------------------------------------------------

                                           (Name of Depositor)

                               20 Madison Avenue Extension, Albany, NY 12203
--------------------------------------------------------------------------------

                (Address of Depositor's Principal Executive Offices) (Zip Code)

              Depositor's Telephone Number, including Area Code (612) 671-3678
--------------------------------------------------------------------------------

                 Mary Ellyn Minenko, IDS Tower 10, Minneapolis, MN 55440-0010
          ----------------------------------------------------------------------

                       (Name and Address of Agent for Service)

It is proposed that this filing will become  effective August 1, 2000 or as soon
as possible.

<PAGE>

Prospectus

______, 2000

American Express Retirement Advisor Variable Annuity

Individual Flexible Premium Deferred Combination Fixed/Variable Annuity

IDS Life of New York Variable Annuity Account


Issued by:        IDS Life Insurance Company of New York (IDS Life of New York)
                  20 Madison Avenue Extention
                  Albany, NY  12203
                  Telephone: 800-541-2251


This prospectus contains information that you should know before investing.  You
also will receive the prospectuses for:
<TABLE>
<CAPTION>
<S>                                                                <C>

o        American Express(R)Variable Portfolio Funds               o        Lazard Retirement Series, Inc.
o        AIM Variable Insurance Funds, Inc.                        o        MFS(R)Variable Insurance TrustSM
o        American Century Variable Portfolios, Inc.                o        Putnam Variable Trust - Class IB Shares
o        Calvert Variable Series, Inc.                             o        Royce Capital Fund
o        Fidelity Variable Insurance Products Funds - Service      o        Third Avenue Variable Series Trust
         Class
o        Franklin Templeton Variable Insurance Products Trust      o        Wanger Advisors Trust
         (FTVIPT) - Class 2                                        o        Warburg Pincus Trust
o        Goldman Sachs Variable Insurance Trust (VIT)
o        Janus Aspen Series: Service Shares
</TABLE>


Please read the prospectuses carefully and keep them for future reference.


The contract  provides for purchase  payment  credits which we may reverse up to
the maximum surrender charge under certain circumstances.


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

An  investment  in  this  contract  is  not a  deposit  of a bank  or  financial
institution  and is not insured or guaranteed by the Federal  Deposit  Insurance
Corporation  or any other  government  agency.  An  investment  in this contract
involves investment risk including the possible loss of principal.

A  Statement  of  Additional  Information  (SAI),  dated  the same  date as this
prospectus,  is incorporated by reference into this prospectus. It is filed with
the SEC and is available  without charge by contacting IDS Life at the telephone
number  above or by  completing  and  sending the order form on the last page of
this  prospectus.  The table of  contents of the SAI is on the last page of this
prospectus.

<PAGE>

Table of Contents

Key Terms................................................................p
The Contract in Brief ...................................................p
Expense Summary..........................................................p
Condensed Financial Information (Unaudited)..............................p
Financial Statements.....................................................p
Performance Information..................................................p
The Variable Account and the Funds.......................................p
The Fixed Account........................................................p
Buying Your Contract.....................................................p
Charges..................................................................p
Valuing Your Investment..................................................p
Making the Most of Your Contract.........................................p
Surrenders...............................................................p
TSA -- Special Surrender Provisions......................................p
Changing Ownership.......................................................p
Benefits in Case of Death................................................p
The Annuity Payout Period................................................p
Taxes....................................................................p
Voting Rights............................................................p
Substitution of Investments..............................................p
About the Service Providers..............................................p
Year 2000................................................................p
Table of Contents of the Statement of Additional Information.............p

<PAGE>

Key Terms

These terms can help you understand details about your contract.

Accumulation  unit -- A measure of the value of each  subaccount  before annuity
payouts begin.

Annuitant -- The person on whose life or life expectancy the annuity payouts are
based.

Annuity  payouts  -- An amount  paid at regular  intervals  under one of several
plans.

Beneficiary  -- The person you  designate  to  receive  benefits  in case of the
owner's or  annuitant's  death while the contract is in force and before annuity
payouts begin.

Close of business -- When the New York Stock Exchange (NYSE) closes,  normally 4
p.m. Eastern time.


Contract -- A deferred annuity contract that permits you to accumulate money for
retirement by making one or more purchase payments.  It provides for lifetime or
other forms of payouts beginning at a specified time in the future.


Contract  value -- The  total  value  of your  contract  before  we  deduct  any
applicable charges.

Contract year -- A period of 12 months,  starting on the effective  date of your
contract and on each anniversary of the effective date.

Fixed account -- An account to which you may allocate purchase payments. Amounts
you  allocate  to  this   account  earn   interest  at  rates  that  we  declare
periodically.


Funds -- Investment options under your contract.  You may allocate your purchase
payments into subaccounts investing in shares of any or all of these funds.


Owner (you, your) -- The person who controls the contract (decides on investment
allocations,  transfers,  payout options,  etc.).  Usually,  but not always, the
owner is also the annuitant.  The owner is responsible for taxes,  regardless of
whether he or she receives the contract's benefits.

Purchase payment credits - An addition we make to your contract value.

Qualified  annuity -- A contract  that you purchase to fund one of the following
tax-deferred  retirement plans that is subject to applicable federal law and any
rules of the plan itself:

o    Individual  Retirement  Annuities  (IRAs) under  Section  408(b) of the
     Internal Revenue Code of 1986, as amended (the Code)

o    Roth IRAs under Section 408A of the Code

o    SIMPLE IRAs under Section 408(p) of the Code

o    Simplified  Employee  Pension (SEP) plans under  Section  408(k) of the
     Code

o    Plans under  Section  401(k) of the Code

o    Custodial  and  trusteed  pension and profit sharing plans under Section
     401(a) of the Code

o    Tax-Sheltered  Annuities (TSAs) under Section 403(b) of the Code


A qualified annuity will not provide any necessary or additional tax deferral if
it is used to fund a retirement plan that is already tax-deferred.


<PAGE>

All other contracts are considered nonqualified annuities.

Settlement date -- The date when annuity payouts are scheduled to begin.

Surrender  value -- The  amount you are  entitled  to receive if you make a full
surrender  from your  contract.  It is the contract  value minus any  applicable
charges.

Valuation date -- Any normal business day, Monday through Friday,  that the NYSE
is open.  Each  valuation  date ends at the close of business.  We calculate the
value of each subaccount at the close of business on each valuation date.

Variable  account -- Consists of separate  subaccounts to which you may allocate
purchase  payments;  each  invests  in  shares  of one  fund.  The value of your
investment in each  subaccount  changes with the  performance  of the particular
fund.

<PAGE>

The Contract in Brief


Purpose:  The purpose of the  contract is to allow you to  accumulate  money for
retirement.  You do  this  by  making  one or more  purchase  payments.  You may
allocate your purchase  payments to the fixed account and/or  subaccounts  under
the contract.  These accounts, in turn, may earn returns that increase the value
of the  contract.  Beginning  at a  specified  time  in the  future  called  the
settlement  date,  the contract  provides  lifetime or other forms of payouts of
your  contract  value.  As in  the  case  of  other  annuities,  it  may  not be
advantageous  for you to  purchase  this  contract as a  replacement  for, or in
addition to, an existing annuity.

A qualified annuity will not provide any necessary or additional tax deferral if
it is used to fund a retirement plan that is tax-deferred. However, the contract
has features other than tax deferral that may make it an appropriate  investment
for your retirement plan. You should compare these features and their costs with
other investment options before deciding to purchase this contract.


Free look period:  You may return your contract to your sales  representative or
to our office  within 10 days after it is  delivered  to you and  receive a full
refund of all your purchase payments. We will not deduct any other charges.

Accounts: Currently, you may allocate your purchase payments among any or
          all of:

o    the  subaccounts,  each  of  which  invests  in a fund  with  a  particular
     investment  objective.  The  value  of  each  subaccount  varies  with  the
     performance of the particular fund in which it invests. We cannot guarantee
     that the  value at the  retirement  date  will  equal or  exceed  the total
     purchase payments you allocate to the subaccounts. (p. __)

o    the  fixed  account,  which  earns  interest  at  a  rate  that  we  adjust
     periodically. (p. __)


Buying your  contract:  Your sales  representative  will help you  complete  and
submit an application. Applications are subject to acceptance at our office. You
may buy a  nonqualified  annuity or a  qualified  annuity.  After  your  initial
purchase payment,  you have the option of making additional purchase payments in
the future. (p. __ )


o    Minimum initial purchase payment - $2,000 ($1,000 for qualified  annuities)
     unless you pay in installments by means of a bank  authorization or under a
     group billing arrangement such as a payroll deduction.

o    Minimum additional purchase payment - $50.

o    Minimum  installment  purchase  payment  -  $50  monthly;  $23.08  biweekly
     (scheduled payment plan billing).

o    Maximum first-year purchase payments - $100,000 to $1,000,000  depending on
     your age.

o    Maximum  purchase  payment for each  subsequent  year - $50,000 to $100,000
     depending upon your age.

<PAGE>

Transfers:  Subject to certain  restrictions you currently may redistribute your
money among the accounts without charge at any time until annuity payouts begin,
and once per contract year among the  subaccounts  after annuity  payouts begin.
You  may  establish  automated  transfers  among  the  accounts.  Fixed  account
transfers are subject to special restrictions. (p.)

Surrenders:  You may surrender  all or part of your  contract  value at any time
before the settlement date. You also may establish automated partial surrenders.
Surrenders  may be subject to charges  and tax  penalties  (including  a 10% IRS
penalty if you  surrender  prior to your reaching age 59 1/2) and may have other
tax consequences; also, certain restrictions apply. (p.)

Changing  ownership:  You may  change  ownership  of a  nonqualified  annuity by
written  instruction,  but  this  may  have  federal  income  tax  consequences.
Restrictions apply to changing ownership of a qualified annuity. (p.)

Benefits in case of death:  If you or the annuitant die before  annuity  payouts
begin,  we will pay the  beneficiary  an amount at least  equal to the  contract
value. (p.)

Annuity  Payouts:  You can apply your contract  value to an annuity  payout plan
that begins on the  settlement  date.  You may choose from a variety of plans to
make  sure  that  payouts  continue  as long as you  like.  If you  purchased  a
qualified  annuity,  the  payout  schedule  must  meet the  requirements  of the
qualified plan. We can make payouts on a fixed or variable basis, or both. Total
monthly  payouts may include amounts from each subaccount and the fixed account.
During the  annuity  payout  period,  you cannot be  invested  in more than five
subaccounts at any one time unless we agree otherwise. (p.)

Taxes:  Generally,  your contract grows  tax-deferred  until you surrender it or
begin to receive payouts.  (Under certain  circumstances,  IRS penalty taxes may
apply.)  Even if you direct  payouts to someone  else,  you will be taxed on the
income if you are the owner. (p.)

Charges:


We assess certain charges in connection with your contract:


o    $30 annual contract administrative charge;


o    for  nonqualified  annuities a 0.95% mortality and expense risk fee (if you
     allocate money to one or more subaccounts);

o    for  qualified  annuities a 0.75%  mortality  and expense  risk fee (if you
     allocate money to one or more subaccounts);


o    surrender charge; and


o    the operating expenses of the funds in which the subaccounts invest.


Expense Summary

The purpose of the following  information  is to help you understand the various
costs and expenses associated with your contract.

You pay no sales charge when you purchase your contract.  We show all costs that
we deduct  directly from your contract or indirectly  from the  subaccounts  and
funds below.  Some expenses may vary as we explain under  "Charges."  Please see
the fund  prospectuses for more  information on the operating  expenses for each
fund.

<PAGE>

Contract owner expenses:

Surrender charge:  contingent  deferred sales charge as a percentage of purchase
payment surrendered.

                        Surrender charge schedule

Years from purchase payment receipt       Surrender charge percentage
                   1                                  7%
                   2                                  7
                   3                                  7
                   4                                  6
                   5                                  5
                   6                                  4
                   7                                  2
               Thereafter                             0


Surrender  charge under Annuity Payout Plan E --Payouts for a specified  period:
The amount equal to the  difference in the present  value of remaining  payments
using the  assumed  investment  rate and such  present  value  using the assumed
investment  rate plus 1.22% for qualified  annuities and 1.42% for  nonqualified
annuities.  In no event  would  your  surrender  charge  exceed 9% of the amount
available for payouts under the plan.


Annual contract administrative charge            $30*

*We will waive this charge when your contract value, or total purchase  payments
less any  payments  surrendered,  is  $50,000  or more on the  current  contract
anniversary.

Annual subaccount expenses (as a percentage of average subaccount value):

Mortality and expense risk fee          0.95% for nonqualified annuities

                                        0.75% for qualified annuities

Annual  operating  expenses  of the funds  (after  fee  waivers  and/or  expense
reimbursements, if applicable, as a percentage of average daily net assets)

<TABLE>
<CAPTION>
<S>                                           <C>          <C>            <C>            <C>
                                              Management                   Other
                                                 Fees      12b-1 fees     Expenses       Total
AXPSM Variable Portfolio
   Blue Chip Advantage Fund                      .56%          .13           .26          .95%1
   Bond Fund                                     .60%          .13           .08          .81%2
   Capital Resource Fund                         .60%          .13           .06          .79%2
   Cash Management Fund                          .51%          .13           .05          .69%2
   Diversified Equity Income Fund                .56%          .13           .26          .95%1

   Emerging Markets Fund                        1.27%          .13           .35         1.75%1

   Extra Income Fund                             .62%          .13           .08          .83%2
   Federal Income Fund                           .61%          .13           .14          .88%1
   Global Bond Fund                              .84%          .13           .12         1.09%2
   Growth Fund                                   .63%          .13           .19          .95%1
   International Fund                            .83%          .13           .11         1.07%2
   Managed Fund                                  .59%          .13           .04          .76%2

<PAGE>


   New Dimensions Fund(R)                                       .61%          .13           .07          .81%2
   S&P 500 Index Fund                                           .37%          .13           --           .50%1
   Small Cap Advantage Fund                                     .79%          .13           .31         1.23%1
   Strategy Aggressive Fund                                     .60%          .13           .07          .80%2
AIM V.I.
   Capital Appreciation Fund                                    .62%          --            .11          .73%3
   Capital Development Fund                                      --           --           1.23         1.23%3,4
American Century VP
   International                                               1.34%          --            --          1.34%5
   Value                                                       1.00%          --            --          1.00%5
Calvert CVS
   Social Balanced Portfolio                                    .70%          --            .16          .86%6
Fidelity VIP
   III Growth & Income Portfolio (Service Class)                .48%          .10           .12          .70%7
   III Mid Cap Portfolio (Service Class)                        .57%          .10           .40         1.07%8
   Overseas Portfolio (Service Class)                           .73%          .10           .18         1.01%7
FTVIPT
   Franklin Real Estate Fund-Class 2                            .56%          .25           .02          .83%10
   Franklin Value Securities Fund-Class 2                       .60%          .25           .21         1.06%9
   Templeton International Smaller Companies Fund-Class 2       .85%          .25           .26         1.36%9
Goldman Sachs VIT
   CORESM Small Cap Equity Fund                                 .75%          --            .25         1.00%11
   CORESM U.S. Equity Fund                                      .70%          --            .20          .90%11
   Mid Cap Value Fund                                           .80%          --            .25         1.05%11
Janus Aspen Series
   Aggressive Growth Portfolio:  Service Shares                 .65%          .25           .02          .92%12
   Global Technology Portfolio:  Service Shares                 .65%          .25           .13         1.03%12
   International Growth Portfolio:  Service Shares              .65%          .25           .11         1.01%12
Lazard Retirement Series
   International Equity Portfolio                               .75%          .25           .25         1.25%13
MFS(R) VIT
   Growth Series-Service Class                                  .75%          .20           .16         1.11%14,15,16
   New Discovery Series-Service Class                           .90%          .20           .17         1.27%14,15,16
Putnam Variable Trust
   Putnam VI International New Opportunities Fund-Class        1.08%          .15           .33         1.56%3
   IB Shares
   Putnam VT Vista Fund-Class IB Shares                         .65%          .15           .10          .90%3
Royce
   Micro-Cap Portfolio                                         1.25%          --            .10         1.35%17
Third Avenue
   Value Portfolio                                              .90%          --            .40         1.30%18
Wanger
   International Small Cap                                     1.25%          --            .24         1.49%19
   U.S. Small Cap                                               .95%          --            .07         1.02%19
Warburg Pincus Trust-
   Emerging Growth Portfolio                                     --           --           1.40         1.40%20
</TABLE>

1Based on  estimated  expenses  after fee waivers  and  expense  reimbursements.
Without  fee waivers and expense  reimbursements  "Other  Expenses"  and "Total"
would be: 0.39% and 1.08% for AXP Variable  Portfolio - Blue Chip  Advantage and
AXP Variable  Portfolio - Diversified  Equity Income Funds,  0.26% and 1.00% for
AXP Variable  Portfolio - Federal Income Fund,  0.32% and 1.08% for AXP Variable
Portfolio - Growth Fund and 0.43% and 1.35% for AXP  Variable  Portfolio - Small
Cap Advantage Fund.


<PAGE>

2The fund's  expense  figures are based on actual  expenses  for the fiscal year
ended Aug. 31, 1999 restated to include a Rule 12b-1  distribution fee of 0.125%
that went into effect Sept.  21, 1999.

3Figures in "Management  Fees",  "12b-1 Fees",  "Other Expenses" and "Total" are
based on actual expenses for the fiscal year ended Dec. 31, 1999.

4Had there been no fee waiver or expenses  reimbursements,  expenses  would have
been: 0.75%, 0.00%, 2.67% and 3.42%.

5The fund has a stepped fee schedule.  As a result,  the fund's  management  fee
rate generally decreases as fund assets increase.

6Net fund operating  expenses after  reductions for fees paid  indirectly  again
restated to reflect an indirect fee for Social  Balanced  would be 0.89%.  Total
expenses have been restated to reflect expenses expected to be incurred in 2000.

7A portion  of the  brokerage  commissions  that  certain  funds pay was used to
reduce fund  expenses.  In addition,  through  arrangements  with certain funds'
custodian, credits realized as a result of uninvested cash balances were used to
reduce a portion of each  applicable  funds'  expenses.  With these  reductions,
"Other  Expenses",  and "Total" presented in the table would have been 0.11% and
0.69% for Growth & Income Portfolio and 0.15% and 0.98% for Overseas Portfolio.

8FMR agreed to reimburse a portion of Mid Cap  Portfolio's  expenses  during the
period. Without this reimbursement, the Portfolio's management fee, distribution
& service fee (12b-1),  other  expenses and total expenses would have been .57%,
 .10%, 2.74% and 3.41% respectively.

9The fund's Class 2  distribution  plan or "Rule 12b-1 plan" is described in the
fund's prospectus.

10Previously  Franklin Real Estate Securities Fund. The fund  administration fee
is paid  indirectly  through the management fee. The fund's Class 2 distribution
plan or "Rule 12b-1 plan" is described in the fund's prospectus.

11The fund's expenses are based on estimated  expenses for the fiscal year ended
Dec. 31, 2000. Goldman Sachs Asset Management and Goldman Sachs Asset Management
International,  the investment  advisers,  have voluntarily  agreed to reduce or
limit  certain other  expenses  (excluding  management  fees,  taxes,  interest,
brokerage fees, litigation, indemnification and other extraordinary expenses) to
the extent such  expenses  exceed the  percentage  stated in the above table (as
calculated  per  annum) of each  fund's  respective  average  daily net  assets.
Without the limitations  described above,  "Other Expenses" and "Total" would be
as follows:  0.75% and 1.50% for CORE Small Cap Equity Fund, 0.42% and 1.22% for
Mid Cap Value Fund  (formerly  the Mid Cap Equity  Fund) and 0.20% and 0.90% for
CORESM U.S. Equity Fund. CORESM is a service mark of Goldman, Sachs & Co.

12Expenses are based on the estimated expenses that the new Service Shares class
of each portfolio  expects to incur in its initial fiscal year. All expenses are
shown without the effect of expense offset arrangements.

13Effective May 1, 1999, the investment  adviser agreed to waive its fees and/or
reimburse the Fund through Dec. 31, 2000 to the extent that Fund expenses exceed
1.25% of the  Fund's  average  daily  net  assets.  Absent  fee  waivers  and/or
reimbursements,  "Other  Expenses" and "Total"  expenses for the year ended Dec.
31, 1999 would have been 11.94% and 12.94% for International Equity.

14Each Series has adopted a  distribution  plan under Rule 12b-1 that permits it
to pay marketing and other fees to support the sales and distribution of service
class shares (these fees are referred to as distribution fees).


15Each  series has an expense  offset  arrangement  which  reduces  the  series'
custodian  fee based upon the amount of cash  maintained  by the series with its
custodian and dividend disbursing agent. The series may enter into other similar
arrangements  and  directed  brokerage  arrangements,  which would also have the
effect of  reducing  the series'  expenses.  "Other  Expenses"  do not take into
account  these  expense  reductions,  and are  therefore  higher than the actual
expenses of the series.  Had these fee reductions been taken into account,  "Net
Expenses" would be lower, and for service class shares would be estimated to be:
1.10% for Growth Series and 1.25% for New Discovery Series.

16MFS has contractually agreed,  subject to reimbursement,  to bear expenses for
the series'  expenses such that "Other  Expenses" (after taking into account the
expense  offset  arrangement  described  above),  do not exceed 0.15%  annually.
Without this  agreement,  "Other  Expenses" and "Total" would be 0.71% and 1.66%
for  Growth  Series  and  1.59%  and  2.69%  for  New  Discovery  Series.  These
contractual fee  arrangements  will continue until at least May 1, 2001,  unless
changed with the consent of the board of trustees which oversees the series.

17Royce has contractually agreed to waive its fees and reimburse expenses to the
extent necessary to maintain the Funds Net Annual Operating  Expense ratio at or
below 1.35%  through Dec. 31, 1999 and 1.99%  through Dec. 31, 2008.  Absent fee
waivers "Other Expenses" and "Total Expenses" would be 0.99% and 2.24% for Royce
Micro-Cap Portfolio.

18These expenses reflect  reimbursements by the Adviser.  The Adviser reimbursed
the Fund  for all  expenses  incurred  by the  Fund in  excess  of 1.30% of Fund
assets.  The fund will repay the Adviser the amount of its  reimbursement for up
to three years  following  the  reimbursement  to the extent Fund  expenses drop
below 1.30%.  The Adviser  expects to continue to  reimburse  the Fund for these
expenses  for  the  foreseeable  future.  Either  the  Fund or the  Adviser  can
terminate this arrangement at any time. Without this  reimbursement,  the Fund's
"Other Expenses" and "Total" would have been 2.05% and 2.95%. Other expenses are
based on estimated amounts for the current fiscal year.

19Actual operating expenses of funds at Dec. 31, 1999.

20Expense ratios are shown after fee waivers and expense  reimbursements  by the
investment   adviser.   The  total   expense   ratio   before  the  waivers  and
reimbursements  would have been  11.16% for  Emerging  Growth  Portfolio  of the
Warburg Pincus Trust.


<PAGE>

Examples:*

You would pay the following  expenses on a $1,000  investment in a  nonqualified
annuity and a 0.95%  mortality  and expense risk fee assuming a 5% annual return
and......

<TABLE>
<CAPTION>

                                                       full surrender at the end    no surrender or selection
                                                          of each time period       of an annuity payout plan
                                                                                     at the end of each time
                                                                                              period
<S>                                                           <C>         <C>           <C>            <C>

                                                              1 year      3 years       1 year         3 years
AXPSM Variable Portfolio
   Blue Chip Advantage Fund                                   $90.06      $132.00       $20.06         $62.00
   Bond Fund                                                   88.62       127.64        18.62          57.64
   Capital Resource Fund                                       88.42       127.02        18.42          57.02
   Cash Management Fund                                        87.39       123.90        17.39          53.90
   Diversified Equity Income Fund                              90.06       132.00        20.06          62.00
   Emerging Markets Fund                                       98.26       156.63        28.26          86.63
   Extra Income Fund                                           88.83       128.27        18.83          58.27
   Federal Income Fund                                         89.34       129.82        19.34          59.82
   Global Bond Fund                                            91.49       136.34        21.49          66.34
   Growth Fund                                                 90.06       132.00        20.06          62.00
   International Fund                                          91.29       135.72        21.29          65.72
   Managed Fund                                                88.11       126.09        18.11          56.09
   New Dimensions Fund(R)                                      88.62       127.64        18.62          57.64
   S&P 500 Index Fund                                          85.45       117.96        15.45          47.96
   Small Cap Advantage Fund                                    92.93       140.67        22.93          70.67
   Strategy Aggressive Fund                                    88.52       127.33        18.52          57.33
AIM V.I.
   Capital Appreciation Fund                                   87.80       125.15        17.80          55.15
   Capital Development Fund                                    92.93       140.67        22.93          70.67
American Century VP
   International                                               94.06       144.06        24.06          74.06
   Value                                                       90.57       133.55        20.57          63.55
Calvert CVS
   Social Balanced Portfolio                                   89.14       129.20        19.14          59.20
Fidelity VIP
   III Growth & Income Portfolio (Service Class)               87.50       124.21        17.50          54.21
   III Mid Cap Portfolio (Service Class)                       91.29       135.72        21.29          65.72
   Overseas Portfolio (Service Class)                          90.67       133.86        20.67          63.86
FTVIPT
   Franklin Real Estate Fund-Class 2                           88.83       128.27        18.83          58.27
   Franklin Value Securities Fund-Class 2                      91.19       135.41        21.19          65.41
   Templeton International Smaller Companies Fund-Class 2      94.26       144.67        24.26          74.67
Goldman Sachs VIT
   CORE Small Cap Equity Fund                                  90.57       133.55        20.57          63.55
   CORE U.S. Equity Fund                                       89.55       130.44        19.55          60.44
   Mid Cap Value Fund                                          91.08       135.10        21.08          65.10


<PAGE>


Janus Aspen Series
   Aggressive Growth Portfolio:  Service Shares               $89.75      $131.07       $19.75         $61.07
   Global Technology Portfolio:  Service Shares                90.88       134.48        20.88          64.48
   International Growth Portfolio:  Service Shares             90.67       133.86        20.67          63.86
Lazard Retirement Series
   International Equity Portfolio                              93.13       141.28        23.13          71.28
MFS(R) VIT
   Growth Series-Service Class                                 91.70       136.96        21.70          66.96
   New Discovery Series-Service Class                          93.34       141.90        23.34          71.90
Putnam Variable Trust
   Putnam VI International New Opportunities Fund-Class        96.31       150.82        26.31          80.82
   IB Shares
   Putnam VT Vista Fund-Class IB Shares                        89.55       130.44        19.55          60.44
Royce
   Micro-Cap Portfolio                                         94.16       144.37        24.16          74.37
Third Avenue
   Value Portfolio                                             93.65       142.83        23.65          72.83
Wanger
   International Small Cap                                     95.59       148.67        25.59          78.67
   U.S. Small Cap                                              90.78       134.17        20.78          64.17
Warburg Pincus Trust-
   Emerging Growth Portfolio                                   94.67       145.91        24.67          75.91


</TABLE>

You would pay the following  expenses on a $1,000  investment in a  nonqualified
annuity and a 0.75%  mortality  and expense risk fee assuming a 5% annual return
and......

<TABLE>
<CAPTION>

                                                       full surrender at the end    no surrender or selection
                                                          of each time period       of an annuity payout plan
                                                                                     at the end of each time
                                                                                              period
<S>                                                           <C>         <C>           <C>            <C>

                                                              1 year      3 years       1 year         3 years
AXPSM Variable Portfolio
   Blue Chip Advantage Fund                                   $88.01      $125.77       $18.01         $55.77
   Bond Fund                                                   86.57       121.40        16.57          51.40
   Capital Resource Fund                                       86.37       120.78        16.37          50.78
   Cash Management Fund                                        85.34       117.65        15.34          47.65
   Diversified Equity Income Fund                              88.01       125.77        18.01          55.77
   Emerging Markets Fund                                       96.21       150.51        26.21          80.51
   Extra Income Fund                                           86.78       122.03        16.78          52.03
   Federal Income Fund                                         87.29       123.59        17.29          53.59
   Global Bond Fund                                            89.44       130.13        19.44          60.13
   Growth Fund                                                 88.01       125.77        18.01          55.77
   International Fund                                          89.24       129.51        19.24          59.51
   Managed Fund                                                86.06       119.84        16.06          49.84
   New Dimensions Fund(R)                                      86.57       121.40        16.57          51.40
   S&P 500 Index Fund                                          83.40       111.68        13.40          41.68
   Small Cap Advantage Fund                                    90.88       134.48        20.88          64.48
   Strategy Aggressive Fund                                    86.47       121.09        16.47          51.09
AIM V.I.
   Capital Appreciation Fund                                   85.75       118.90        15.75          48.90
   Capital Development Fund                                    90.88       134.48        20.88          64.48
American Century VP
   International                                               92.01       137.89        22.01          67.89
   Value                                                       88.52       127.33        18.52          57.33


<PAGE>


Calvert CVS
   Social Balanced Portfolio                                  $87.09      $122.97       $17.09         $52.97


Fidelity VIP
   III Growth & Income Portfolio (Service Class)               85.45       117.96        15.45          47.96
   III Mid Cap Portfolio (Service Class)                       89.24       129.51        19.24          59.51
   Overseas Portfolio (Service Class)                          88.62       127.64        18.62          57.64
FTVIPT
   Franklin Real Estate Fund-Class 2                           86.78       122.03        16.78          52.03
   Franklin Value Securities Fund-Class 2                      89.14       129.20        19.14          59.20
   Templeton International Smaller Companies Fund-Class 2      92.21       138.50        22.21          68.50
Goldman Sachs VIT
   CORE Small Cap Equity Fund                                  88.52       127.33        18.52          57.33
   CORE U.S. Equity Fund                                       87.50       124.21        17.50          54.21
   Mid Cap Value Fund                                          89.03       128.89        19.03          58.89


Janus Aspen Series
   Aggressive Growth Portfolio:  Service Shares                87.70       124.84        17.70          54.84
   Global Technology Portfolio:  Service Shares                88.83       128.27        18.83          58.27
   International Growth Portfolio:  Service Shares             88.62       127.64        18.62          57.64


Lazard Retirement Series
   International Equity Portfolio                              91.08       135.10        21.08          65.10


MFS(R) VIT
   Growth Series-Service Class                                 89.65       130.75        19.65          60.75
   New Discovery Series-Service Class                          91.29       135.72        21.29          65.72


Putnam Variable Trust
   Putnam VI International New Opportunities Fund-Class        94.26       144.67        24.26          74.67
   IB Shares
   Putnam VT Vista Fund-Class IB Shares                        87.50       124.21        17.50          54.21
Royce
   Micro-Cap Portfolio                                         92.11       138.19        22.11          68.19
Third Avenue
   Value Portfolio                                             91.60       136.65        21.60          66.65
Wanger
   International Small Cap                                     93.54       142.52        23.54          72.52
   U.S. Small Cap                                              88.73       127.96        18.73          57.96
Warburg Pincus Trust-
   Emerging Growth Portfolio                                   92.62       139.74        22.62          69.74

</TABLE>

You should not  consider  these  examples as  representations  of past or future
expenses. Actual expenses may be more or less than those shown.

Condensed Financial Information (Unaudited)

We have not provided any condensed  financial  information  for the  subaccounts
because they are new and do not have any history.

Financial Statements


You can find  our  audited  financial  statements  in the SAI.  The SAI does not
include the audited financial statements of the subaccounts because they are new
and do not have any performance.


<PAGE>

Performance Information

Performance  information  for the  subaccounts  may appear  from time to time in
advertisements or sales literature. This information reflects the performance of
a  hypothetical  investment in a particular  subaccount  during a specified time
period.  Currently,  we do not  provide  any  performance  information  for  the
subaccounts because they are new and have not had any activity to date. However,
we show performance  from the commencement  date of the funds as if the contract
existed at that time, which it did not. Although we base performance  figures on
historical earnings, past performance does not guarantee future results.

We include  non-recurring  charges  (such as surrender  charges) in total return
figures, but not in yield quotations.  Excluding  non-recurring charges in yield
calculations increases the reported value.

Total return figures reflect deduction of all applicable charges, including:

o        contract administrative charge,

o        mortality and expense risk fee, and

o        surrender charge (assuming a surrender at the end of the illustrated
         period).

We also show optional  total return  quotations  that do not reflect a surrender
charge deduction (assuming no surrender). We may show total return quotations by
means of schedules, charts or graphs.

Average annual total return is the average annual  compounded  rate of return of
the  investment  over a period of one,  five and ten years (or up to the life of
the subaccount if it is less than ten years old).

Cumulative  total return is the cumulative  change in the value of an investment
over a specified time period.  We assume that income earned by the investment is
reinvested. Cumulative total return generally will be higher than average annual
total return.

Annualized  simple  yield (for  subaccounts  investing  in money  market  funds)
"annualizes"  the income  generated  by the  investment  over a given  seven-day
period.  That is, we assume the  amount of income  generated  by the  investment
during the period will be generated  each  seven-day  period for a year. We show
this as a percentage of the investment.

Annualized  compound yield (for subaccounts  investing in money market funds) is
calculated like simple yield except that we assume the income is reinvested when
we annualize it.  Compound yield will be higher than the simple yield because of
the compounding effect of the assumed reinvestment.

Annualized  yield (for  subaccounts  investing in income funds)  divides the net
investment  income  (income less expenses) for each  accumulation  unit during a
given 30-day  period by the value of the unit on the last day of the period.  We
then convert the result to an annual percentage.

You  should  consider  performance   information  in  light  of  the  investment
objectives,  policies,  characteristics  and  quality  of the fund in which  the
subaccount  invests and the market  conditions during the specified time period.
Advertised   yields  and  total  return  figures  include  charges  that  reduce
advertised performance. Therefore, you should not compare subaccount performance
to that of mutual funds that sell their shares directly to the public.  (See the
SAI for a further  description  of methods  used to  determine  total return and
yield.)

If you would  like  additional  information  about  actual  performance,  please
contact us.

<PAGE>

The Variable Account and the Funds

You may  allocate  payments  to any or all of the  subaccounts  of the  variable
account that invest in shares of the following funds:

<TABLE>
<CAPTION>
<S>              <C>                         <C>                                              <C>
                                                                                              Investment Advisor or
Subaccount       Investing In                Investment Objectives and Policies:              Manager

      BC7        AXPSM Variable Portfolio -  Objective: long-term total return exceeding      IDS Life, investment
      BC8        Blue Chip Advantage Fund    that of the U.S. stock market. Invests           manager; American
                                             primarily in common stocks of companies          Express Financial
                                             included in the unmanaged S&P 500 Index.         Corporation (AEFC)
                                                                                              investment advisor.


      BD7        AXPSM Variable Portfolio -  Objective: high level of current income while    IDS Life, investment
      BD8        Bond Fund                   conserving the value of the investment for the   manager; AEFC
                                             longest time period. Invests primarily in bonds  investment advisor.
                                             and other debt obligations.



      CR7        AXPSM Variable Portfolio -  Objective: capital appreciation. Invests         IDS Life, investment
      CR8        Capital Resource Fund       primarily in U.S. common stocks and other        manager; AEFC
                                             securities convertible into common stocks.       investment advisor.


      CM7        AXPSM Variable Portfolio -  Objective: maximum current income consistent     IDS Life, investment
      CM8        Cash Management Fund        with liquidity and conservation of capital.      manager; AEFC
                                             Invests in money market securities.              investment advisor.

      DE7        AXPSM Variable Portfolio -  Objective: high level of current income and, as  IDS Life, investment
      DE8        Diversified Equity Income   a secondary goal, steady growth of capital.      manager; AEFC
                 Fund                        Invests primarily in dividend-paying common and  investment advisor.
                                             preferred stocks.


      EM7        AXPSM Variable Portfolio -  Objective: long-term capital growth. Invests     IDS Life, investment
      EM8        Emerging Markets Fund       primarily in equity securities of companies in   manager; AEFC
                                             emerging markets.                                investment advisor;
                                                                                              American Express Asset
                                                                                              Management
                                                                                              International, Inc., a
                                                                                              wholly-owned subsidiary
                                                                                              of AEFC, is the
                                                                                              sub-investment advisor.


      EI7        AXPSM Variable Portfolio -  Objective: high current income, with capital     IDS Life, investment
      EI8        Extra Income Fund           growth as a secondary objective. Invests         manager; AEFC
                                             primarily in high-yielding, high-risk corporate  investment advisor.
                                             bonds issued by U.S. and foreign companies and
                                             governments.


      FI7        AXPSM Variable Portfolio -  Objective: high level of current income and      IDS Life, investment
      FI8        Federal Income Fund         safety of principal consistent with an           manager; AEFC
                                             investment in U.S. government and government     investment advisor.
                                             agency securities. Invests primarily in debt
                                             obligations issued or guaranteed as to
                                             principal and interest by the U.S. government,
                                             its agencies or instrumentalities.


      GB7        AXPSM Variable Portfolio -  Objective: high total return through income and  IDS Life, investment
      GB8        Global Bond Fund            growth of capital. Non-diversified mutual fund   manager; AEFC
                                             that invests primarily in debt obligations of    investment advisor.
                                             U.S. and foreign issuers.


<PAGE>


     GR7       AXPSM Variable Portfolio -   Objective: long-term capital growth. Invests        IDS Life, investment
     GR8       Growth Fund                  primarily in common stocks and securities           manager; AEFC
                                            convertible into common stocks that appear to       investment advisor.
                                            offer growth opportunities.


     IE7       AXPSM Variable Portfolio -   Objective: capital appreciation. Invests primarily  IDS Life, investment
     IE8       International Fund           in common stock or convertible securities of        manager; AEFC
                                            foreign issuers that offer growth potential.        investment advisor.
                                                                                                American Express
                                                                                                Asset Management
                                                                                                International, Inc.,
                                                                                                a wholly-owned
                                                                                                subsidiary of AEFC,
                                                                                                is the
                                                                                                sub-investment
                                                                                                advisor.


     MF7       AXPSM Variable Portfolio -   Objective: maximum total investment return through  IDS Life, investment
     MF8       Managed Fund                 a combination of capital growth and current         manager; AEFC
                                            income. Invests primarily in stocks, convertible    investment advisor.
                                            securities, bonds and other debt securities.

     ND7       AXPSM Variable Portfolio -   Objective: long-term growth of capital. Invests     IDS Life, investment
     ND8       New Dimensions Fund(R)         primarily in common stocks of U.S. and foreign      manager; AEFC
                                            companies showing potential for significant growth. investment advisor.


     IV7       AXPSM Variable Portfolio -   Objective: long-term capital appreciation. Invests  IDS Life, investment
     IV8       S&P 500 Index Fund           primarily in securities that are expected to        manager; AEFC
                                            provide investment results that correspond to the   investment advisor.
                                            performance of the S&P 500 Index.



     SC7       AXPSM Variable Portfolio -   Objective: long-term capital growth. Invests        IDS Life, investment
     SC8       Small Cap Advantage Fund     primarily in equity stocks of small companies that  manager; AEFC
                                            are often included in the S&P SmallCap 600 Index    investment advisor.
                                            or the Russell 2000 Index.

     SA7       AXPSM Variable Portfolio -   Objective: capital appreciation. Invests primarily  IDS Life, investment
     SA8       Strategy Aggressive Fund     in common stocks of small-and medium-size           manager; AEFC
                                            companies.                                          investment advisor.

     7CA       AIM V.I. Capital             Objective: growth of capital.  Invests primarily    A I M Advisors, Inc.
     8CA       Appreciation Fund            in common stocks, with emphasis on medium- or
                          small-sized growth companies.

     7CD       AIM V.I. Capital             Objective: long term growth of capital.  Invests    A I M Advisors, Inc.
     8CD       Development Fund             primarily in securities (including common stocks,
                                            convertible securities and bonds) of small- and
                                            medium-sized companies.


     7IF       American Century VP          Objective: long term capital growth. Invests        American Century
     8IF       International                primarily in stocks of growing foreign companies.   Investment
                                                                                                Management, Inc.


<PAGE>




     7VA       American Century VP Value    Objective: long-term capital growth, with income    American Century
     8VA                                    as a secondary objective. Invests primarily in      Investment
                                            securities that management believes to be           Management, Inc.
                                            undervalued at the time of purchase.

     7SR       Calvert Variable Series,     Objective: income and capital growth.  Invests      Calvert Asset
     8SR       Inc. Social Balanced         primarily in stocks, bonds and money market         Management Company,
               Portfolio                    instruments which offer income and capital growth   Inc. (CAMCO),
                                            opportunity and which satisfy the investment and    investment advisor.
                                            social criteria.                                    NCM Capital
                                                                                                Management Group,
                                                                                                Inc. is the
                                                                                                investment subadvisor.


     7GI       Fidelity VIP III Growth &    Objective: high total return through a combination  Fidelity Management &
     8GI       Income Portfolio (Service    of current income and capital appreciation.         Research Company
               Class)                       Invests primarily in common stocks with a focus on  (FMR), investment
                                            those that pay current dividends and show           manager; FMR U.K. and
                                            potential for capital appreciation.                 FMR Far East,
                                                                                                sub-investment
                                                                                                advisors.

     7MP       Fidelity VIP III Mid Cap     Objective: long-term growth of capital. Invests     FMR, investment
     8MP       Portfolio (Service Class)    primarily in medium market capitalization common    manager; FMR U.K. and
                                            stocks.                                             FMR Far East,
                                                                                                sub-investment
                                                                                                advisors.

     7OS       Fidelity VIP Overseas        Objective: long-term growth of capital. Invests     FMR, investment
     8OS       Portfolio (Service Class)    primarily in common stocks of foreign securities.   manager; FMR U.K.,
                                                                                                FMR Far East, Fidelity
                                                                                                International Investment
                                                                                                Advisors (FIIA) and
                                                                                                FIIA U.K., sub-investment
                                                                                                advisors.


     7RE        FTVIPT  Franklin Real Estate  Objective:  capital  appreciation  with a         Franklin Advisers, Inc.
                Fund - Class 2 (previously    secondary goal to earn current income.
                Franklin Real Estate          Invests primarily in securities of
                Securities Fund)              companies operating in the real estate
                                              industry, primarily equity real estate
                                              investment trusts (REITS).

     7SI       FTVIPT Franklin Value        Objective: long-term total return. Invests          Franklin Advisory
     8SI       Securities Fund - Class 2    primarily in equity securities of companies the     Services, LLC
                                            manager believes are significantly undervalued.

     7IS       FTVIPT Templeton             Objective: long-term capital appreciation. Invests  Templeton Investment
     8IS       International Smaller        primarily in equity securities of smaller           Counsel, Inc.
               Companies Fund - Class 2     companies located outside the U.S., including
                                            those in emerging markets.

     7SE       Goldman Sachs VIT CORE       Objective: long-term growth of capital. Invests     Goldman Sachs Asset
     8SE       Small Cap Equity Fund        primarily in a broadly diversified portfolio of     Management
                                            equity securities of U.S. issuers which are
                                            included in the Russell 2000 Index at the time of
                                            investment.
<PAGE>



     7UE       Goldman Sachs VIT CORE U.S.  Objective: long-term growth of capital and          Goldman Sachs Asset
     8UE       Equity Fund                  dividend income. Invests primarily in a broadly     Management
                                            diversified portfolio of large-cap and blue chip
                                            equity securities representing all major sectors
                                            of the U.S. economy.

     7MC       Goldman Sachs VIT Mid Cap    Objective: long-term capital appreciation.          Goldman Sachs Asset
     8MC       Value Fund                   Invests primarily in mid-capitalization companies   Management
                                            within   the  range  of  the  market
                                            capitalization      of     companies
                                            constituting   the  Russell   Midcap
                                            Value   index   at   the   time   of
                                            investment.

     7AG       Janus Aspen Series           Objective: long-term growth of capital.             Janus Capital
     8AG       Aggressive Growth            Non-diversified mutual fund that invests primarily
               Portfolio: Service Shares    in common stocks selected for their growth
                                            potential. Normally invests at least 50% of its
                                            equity assets in medium-sized companies.

     7GT       Janus Aspen Series Global    Objective: long-term growth of capital.             Janus Capital
     8GT       Technology Portfolio:        Non-diversified mutual fund that invests primarily
               Service Shares               in equity securities of U.S. and foreign companies
                                            selected for their growth potential. Normally
                                            invests at least 65% of total assets in securities
                                            of companies that the portfolio manager believes
                                            will benefit significantly from advancements or
                                            improvements in technology.


     7IG       Janus Aspen Series           Objective: long-term growth of capital. Invests at  Janus Capital
     8IG       International Growth         least 65%of its total assets in securities of
               Portfolio: Service Shares    issuers from at least five different countries,
                                            excluding the U.S. It may at times invest all of
                                            its assets in fewer than five countries or even a
                                            single country.

     7IP       Lazard Retirement Series     Objective: long-term capital appreciation. Invests  Lazard Asset
     8IP       International Equity         primarily in equity securities, principally common  Management
               Portfolio                    stocks of relatively large non-U.S. companies
                                            (those whose total market value is more than $1
                                            billion) that the Investment Manager believes are
                                            undervalued based on their earnings, cash flow or
                                            asset values.

     7MG       MFS(R) VIT Growth Series -     Objective: long-term growth of capital and future   MFS Investment
     8MG       Service Class                income.  Invests at least 80% of its total assets   Management(R)
                                            in   common   stocks   and   related
                                            securities  of  companies  which MFS
                                            believes  offer  better than average
                                            prospects for long-term growth.


     7MD       MFS(R) VIT New Discovery       Objective: capital appreciation. Invests primarily  MFS Investment
     8MD       Series - Service Class       in equity securities of emerging growth companies.  Management(R)

     7IN       Putnam VT International New  Objective: long-term capital appreciation. Invests  Putnam Investment
     8IN       Opportunities Fund - Class   primarily in a diversified portfolio of common      Management, Inc.
               IB                           Shares stocks that Putnam Management
                                            believes     have      above-average
                                            potential for capital appreciation.

     7VS       Putnam VT Vista Fund -       Objective: capital appreciation. Invests primarily  Putnam Investment
     8VS       Class IB Shares              in a diversified portfolio of common stocks that    Management, Inc.
                                            Putnam Management  believes have the
                                            potential for above-average  capital
                                            appreciation.

<PAGE>

     7MI        Royce Micro-Cap Portfolio   Objective: long-term growth of capital. Invests     Royce & Associates,
     8MI                                    primarily in a broadly diversified portfolio of     Inc.
                                            equity securities issued by micro-cap companies
                                            (companies with stock market capitalizations below
                                            $300 million).

     7SV       Third Avenue Value Portfolio Objective: long-term capital appreciation. Invests  EQSF, Inc.
     8SV                                    primarily in common stocks of well-financed
                                            companies at a substantial discount to what the
                                            Advisor believes is their true value.

     7IT       Wanger International Small   Objective: long-term growth of capital.  Invests    Wanger Asset
     8IT       Cap                          primarily in stocks of small- and medium-size       Management, L.P.
                                            non-U.S. companies.

     7SP       Wanger U.S. Small Cap        Objective: long-term growth of capital.  Invests    Wanger Asset
     8SP                                    primarily in stocks of small- and medium-size U.S.  Management, L.P.
                                            companies.

     7EG       Warburg Pincus Trust -       Objective: maximum capital appreciation. Invests    Warburg Pincus Asset
     8EG       Emerging Growth Portfolio    primarily in equity securities of small or medium   Management, Inc.
                                            sized U.S. emerging-growth companies.
</TABLE>


The  investment  objectives and policies of some of the funds are similar to the
investment  objectives  and policies of other  mutual  funds that an  investment
advisor or its  affiliates  manage.  Although the objectives and policies may be
similar,  each fund will have its own  portfolio  holdings  and its own fees and
expenses. Accordingly, each fund will have its own investment results, and those
results  may differ  significantly  from other  funds  with  similar  investment
objectives and policies.


The investment  managers and advisors cannot  guarantee that the funds will meet
their  investment  objectives.  Please read the fund  prospectuses for facts you
should  know  before  investing.   These  prospectuses  are  also  available  by
contacting  us at the  address  or  telephone  number on the first  page of this
prospectus.


All funds are  available  to serve as the  underlying  investments  for variable
annuities.  Some funds also are  available  to serve as  investment  options for
variable  life  insurance  policies and  tax-deferred  retirement  plans.  It is
possible  that in the future,  it may be  disadvantageous  for variable  annuity
accounts and variable life insurance  accounts  and/or  tax-deferred  retirement
plans to invest in the available funds simultaneously.

Although the insurance  company and the funds do not currently  foresee any such
disadvantages, the boards of directors or trustees of the appropriate funds will
monitor  events in order to identify  any  material  conflicts  between  annuity
owners,  policy owners and  tax-deferred  retirement plans and to determine what
action,  if any,  should be taken in response to a conflict.  If a board were to
conclude  that it should  establish  separate  funds for the  variable  annuity,
variable life insurance and tax-deferred retirement plan accounts, you would not
bear any expenses  associated with establishing  separate funds. Please refer to
the fund prospectuses for risk disclosure regarding simultaneous  investments by
variable  annuity,  variable life  insurance and  tax-deferred  retirement  plan
accounts.

The Internal  Revenue  Service  (IRS) issued final  regulations  relating to the
diversification requirements under Section 817(h) of the Code. Each fund intends
to comply with these requirements.


The variable  account was established  under New York law on April 17, 1996, and
the subaccounts are registered  together as a single unit investment trust under
the Investment  Company Act of 1940 (the 1940 Act). This  registration  does not
involve any  supervision of our management or investment  practices and policies
by the SEC. All obligations  arising under the contracts are general obligations
of IDS Life.

<PAGE>

The variable  account meets the  definition of a separate  account under federal
securities laws. We credit or charge income, capital gains and capital losses of
each subaccount only to that  subaccount.  State insurance law prohibits us from
charging a subaccount with liabilities of any other subaccount or of our general
business.  The variable  account  includes other  subaccounts that are available
under contracts that are not described in this prospectus.


The  U.S.  Treasury  and the IRS  indicated  that  they may  provide  additional
guidance on investment control.  This concerns how many variable  subaccounts an
insurance  company may offer and how many  exchanges  among  subaccounts  it may
allow before the contract owner would be currently taxed on income earned within
subaccount  assets.  At this time, we do not know what the  additional  guidance
will be or when  action  will be taken.  We  reserve  the  right to  modify  the
contract,  as  necessary,  so that the  owner  will not be  subject  to  current
taxation as the owner of the subaccount assets.


We intend to comply with all federal tax laws so that the contract  continues to
qualify as an annuity for federal  income tax purposes.  We reserve the right to
modify the contract as necessary to comply with any new tax laws.

The Fixed Account


You also may  allocate  purchase  payments  to the  fixed  account.  We back the
principal and interest  guarantees  relating to the fixed account.  The value of
the fixed  account  increases  as we credit  interest to the  account.  Purchase
payments and transfers to the fixed account become part of our general  account.
We credit  interest daily and compound it annually.  We will change the interest
rates from time to time at our discretion.  These rates will be based on various
factors  including,  but not limited to, the interest rate environment,  returns
earned on investments backing these annuities, the rates currently in effect for
new  and  existing  company  annuities,  product  design,  competition  and  the
company's revenues and expenses.


Interests in the fixed account are not required to be  registered  with the SEC.
The SEC staff does not review the  disclosures  in this  prospectus on the fixed
account.  Disclosures  regarding the fixed account,  however,  may be subject to
certain generally applicable  provisions of the federal securities laws relating
to the  accuracy and  completeness  of  statements  made in  prospectuses.  (See
"Making  the Most of Your  Contract  -Transfer  policies"  for  restrictions  on
transfers involving the fixed account.)

Buying Your Contract

You can fill out an  application  and send it along with your  initial  purchase
payment to our  office.  As the owner,  you have all rights and may  receive all
benefits under the contract. You can own a nonqualified annuity in joint tenancy
with  rights of  survivorship  only in  spousal  situations.  You  cannot  own a
qualified  annuity  in  joint  tenancy.  You can buy a  contract  or  become  an
annuitant if you are 90 or younger.

When you apply, you may select:

o    the fixed account and/or subaccounts in which you want to invest;

o    how you want to make purchase payments; and

o    a beneficiary.

The contract  provides for allocation of purchase payments to the subaccounts of
the variable account and/or to the fixed account in even 1% increments.

If your  application  is complete,  we will  process it and apply your  purchase
payment to the fixed account and  subaccounts  you selected  within two business
days after we receive it at our office. If we accept your  application,  we will
send you a contract.  If we cannot accept your application  within five business
days,  we will  decline it and return your  payment.  We will credit  additional
purchase  payments you make to your  accounts on the  valuation  date we receive
them. We will value the additional  payments at the next accumulation unit value
calculated after we receive your payments at our office.

<PAGE>

The settlement date
Annuity  payouts are scheduled to begin on the settlement  date. When we process
your  application,  we will establish the settlement  date to the maximum age or
date described below. You can also select a date within the maximum limits.  You
can  align  this date with your  actual  retirement  from a job,  or it can be a
different  future  date,  depending  on your  needs  and  goals  and on  certain
restrictions.  You  also can  change  the  date,  provided  you send us  written
instructions at least 30 days before annuity payouts begin.


For nonqualified annuities and Roth IRAs, the settlement date must be:


o    no earlier than the 60th day after the contract's effective date; and

o    no later than the annuitant's 90th birthday.


For  qualified  annuities  except  Roth IRAs,  to avoid IRS penalty  taxes,  the
settlement date generally must be:


o    on or after the date the annuitant reaches age 59 1/2; and


o    for  IRAs,  SIMPLE  IRAs and  SEPs,  by April 1 of the year  following  the
     calendar year when the annuitant reaches age 70 1/2; or


o    for all other  qualified  annuities,  by April 1 of the year  following the
     calendar year when the annuitant reaches age 70 1/2, or, if later,  retires
     (except that 5% business  owners may not select a  settlement  date that is
     later than April 1 of the year  following the calendar year when they reach
     age 70 1/2).

If you take the  minimum IRA or TSA  distributions  as required by the Code from
another tax-qualified investment, or in the form of partial surrenders from this
contract, annuity payouts can start as late as the annuitant's 90th birthday.

Beneficiary

If death benefits  become payable before the settlement  date while the contract
is in force and before annuity payouts begin, we will pay your named beneficiary
all or part of the contract value. If there is no named beneficiary, then you or
your estate will be the  beneficiary.  (See "Benefits in Case of Death" for more
about beneficiaries.)

Purchase payments:

    Minimum allowable purchase payments*
<TABLE>
<CAPTION>
     <S>                                                    <C>
     If paying by installments under a scheduled payment    If paying by any other method:
       plan:                                                  $1,000 initial payment for qualified annuities
       $23.08 biweekly, or                                    $2,000 initial payment for nonqualified annuities
       $50 per month                                          $50 for any additional payments
</TABLE>

*  Installments  must total at least $600 in the first year.  If you do not make
any purchase  payments for 36 months,  and your previous  payments total $600 or
less,  we have the  right to give you 30 days'  written  notice  and pay you the
total value of your contract in a lump sum.

    Maximum  allowable  purchase  payments**  based  on  the  age  of you or the
    annuitant, whoever is older, on the effective date of the contract:

       For the first year:                      For each subsequent year:
         $1,000,000 up to age 85                    $100,000 up to age 85
         $100,000 for ages 86 to 90                 $50,000 for ages 86-90


** These limits apply in total to all IDS Life of New York annuities you own. We
reserve  the right to increase  maximum  limits.  For  qualified  annuities  the
tax-deferred retirement plan's limits on annual contributions also apply.


<PAGE>

How to make purchase payments

1
By letter:

Send your check along with your name and contract number to:

Regular mail:
IDS Life Insurance Company of New York
Box 5144
Albany, NY  12205

Express mail:
IDS Life Insurance Company of New York
20 Madison Avenue Extention
Albany, NY  12203

2
By scheduled payment plan

We can help you set up:

o    an automatic  payroll  deduction,  salary  reduction or other group billing
     arrangement; or

o    a bank authorization.

Charges

Contract administrative charge
We charge this fee for establishing and maintaining your records.  We deduct $30
from the contract value on your contract anniversary at the end of each contract
year. We prorate this charge among the  subaccounts and the fixed account in the
same  proportion  your  interest in each  account  bears to your total  contract
value.

We will waive this charge when your contract value,  or total purchase  payments
less any  payments  surrendered,  is  $50,000  or more on the  current  contract
anniversary.

If you  surrender  your  contract,  we will  deduct  the  charge  at the time of
surrender  regardless of the contract value or purchase payments made. We cannot
increase the annual contract  administrative  charge and it does not apply after
annuity payouts begin or when we pay death benefits.

Mortality and expense risk fee
We charge this fee daily to the subaccounts. The unit values of your subaccounts
reflect this fee. For nonqualified annuities the fee totals 0.95% of the average
daily net assets on an annual  basis.  For  qualified  annuities  the fee totals
0.75% of the average  daily net assets on an annual  basis.  This fee covers the
mortality  and expense  risk that we assume.  Approximately  two-thirds  of this
amount  is for our  assumption  of  mortality  risk,  and  one-third  is for our
assumption of expense risk. This fee does not apply to the fixed account.

<PAGE>

Mortality  risk arises  because of our  guarantee to pay a death benefit and our
guarantee to make annuity  payouts  according to the terms of the  contract,  no
matter  how long a  specific  annuitant  lives and no matter how long our entire
group of annuitants live. If, as a group, annuitants outlive the life expectancy
we assumed in our  actuarial  tables,  then we must take money from our  general
assets to meet our obligations.  If, as a group,  annuitants do not live as long
as expected, we could profit from the mortality risk fee.

Expense  risk arises  because we cannot  increase  the  contract  administrative
charge and this charge may not cover our expenses.  We would have to make up any
deficit from our general assets.

The  subaccounts  pay us the  mortality  and  expense  risk fee they  accrued as
follows:

o    first,  to the  extent  possible,  the  subaccounts  pay  this fee from any
     dividends distributed from the funds in which they invest;

o    then,  if necessary,  the funds redeem  shares to cover any remaining  fees
     payable.

We may use any  profits we realize  from the  subaccounts'  payment to us of the
mortality  and expense  risk fee for any proper  corporate  purpose,  including,
among others,  payment of distribution (selling) expenses. We do not expect that
the surrender charge,  discussed in the following  paragraphs,  will cover sales
and distribution expenses.

Surrender charge
If you surrender all or part of your contract, you may be subject to a surrender
charge.  A surrender  charge  applies if all or part of the surrender  amount is
from purchase payments we received within seven (7) years before surrender.

For purposes of calculating any surrender charge,  we treat amounts  surrendered
from your contract value in the following order:

1.   First,  we surrender any contract  earnings  (contract  value less purchase
     payments  received  and not  previously  surrendered).  We do not  assess a
     surrender charge on contract earnings.

NOTE: We determine  contract  earnings by looking at the entire  contract value,
not the earnings of any particular subaccount or the fixed account.

2.   Next, in each contract  year,  we surrender  amounts  totaling up to 10% of
     your prior contract  anniversary contract value, but only to the extent not
     included  and  surrendered  in number one  above.  (Your  initial  purchase
     payment is considered the prior contract  anniversary contract value during
     the first  contract  year.)  We do not  assess a  surrender  charge on this
     amount.

3.   Next we surrender  purchase payments received prior to the surrender charge
     period. We do not assess a surrender charge on these purchase payments.

4.   Finally,  if necessary,  we surrender  purchase  payments received that are
     still within the surrender charge period.  We surrender these payments on a
     "first-in,  first-out"  (FIFO)  basis.  We do assess a surrender  charge on
     these payments.

<PAGE>

We  determine  your  surrender  charge  by  multiplying  each of  your  payments
surrendered by the applicable  surrender charge percentage,  and then adding the
total surrender charges.

The surrender  charge  percentage  depends on the number of years since you made
the payments that are surrendered:

                 Surrender charge schedule

 Years from purchase payment    Surrender charge percentage
           receipt
              1                              7%
              2                              7
              3                              7
              4                              6
              5                              5
              6                              4
              7                              2
          Thereafter                         0


For a partial  surrender  that is  subject  to a  surrender  charge,  the amount
deducted  for the  surrender  charge will be a  percentage  of the total  amount
surrendered. We will deduct the charge from the value remaining after we pay you
the amount you requested.  Example: Assume you request a surrender of $1,000 and
there is a 7%  surrender  charge.  The  surrender  charge is $75.26  for a total
surrender  amount of  $1,075.26.  This charge  represents 7% of the total amount
surrendered  and we deduct it from the contract value remaining after we pay you
the $1,000 you requested.

Surrender  charge under Annuity  Payout Plan E: Payouts for a specified  period.
Under this payout plan, you can choose to take a surrender.  The amount that you
can  surrender  is the present  value of any  remaining  variable  payouts.  For
qualified  contracts,  the discount rate we use in the calculation will be 4.72%
if the assumed  investment rate is 3.5% and 6.22% if the assumed investment rate
is 5%. For nonqualified  contracts,  the discount rate we use in the calculation
will be 4.92% if the  assumed  investment  rate is 3.5% and 6.42% if the assumed
investment  rate is 5%.  The  surrender  charge  is equal to the  difference  in
discount values using the above discount rates and the assumed  investment rate.
In no event would your  surrender  charge exceed 9% of the amount  available for
payouts under the plan.


Surrender charge calculation example

The  following is an example of the  calculation  we would make to determine the
surrender charge on a contract:


o    The  contract  date is July 1, 2001 with a contract  year of July 1 through
     June 30 and with an anniversary date of July 1 each year; and

o    We received these payments:
     -$10,000 July 1, 2001;
     -$ 8,000 Dec. 31, 2006
     -$ 6,000 Feb. 20, 2009; and

o    The owner  surrenders the contract for its total surrender value of $26,500
     on Aug. 5, 2010 and had not made any other surrenders  during that contract
     year; and

o    The prior anniversary July 1, 2009 contract value was $28,000.



<PAGE>



Surrender charge    Explanation
     $    0         $2,500 is contract earnings surrendered without charge; and

          0         $300 is 10% of the prior anniversary contract value that is
                    in excess of contract earnings surrendered without charge
                   (from above). 10% of $28,000= $2,800 minus $2,500 = $300

          0         $10,000 July 1, 2001  payment was received  eight or
                    more  years  before  surrender  and  is  surrendered
                    without surrender charge; and

        400         $8,000 Dec. 31, 2006 payment is in its fifth year from
                    receipt, surrendered with a 5% surrender charge; and

        420         $6,000 Feb. 20, 2009 payment is in its third year from
                    receipt, surrendered with a 7% surrender charge.

       ____
       $820

For a partial  surrender  that is subject to a surrender  charge,  the amount we
actually  surrender  from your  contract will be the amount you request plus any
applicable surrender charge. We apply the surrender charge to this total amount.
We pay you the  amount  you  requested.  If you  make a full  surrender  of your
contract, we also will deduct the $30 contract administrative charge.

Waiver of surrender charges

We do not assess surrender charges for:

o    surrenders of any contract earnings;

o    surrenders of amounts totaling up to 10% of your prior contract anniversary
     contract value to the extent it exceeds contract earnings;

o    required minimum  distributions from a qualified annuity (for those amounts
     required to be distributed from the contract described in this prospectus);

o    contracts settled using an annuity payout plan;

o    amounts we refund to you during the free look period*; and

o    death benefits*.

* However,  we will reverse certain  purchase  payment credits up to the maximum
surrender charge. (See "Valuing Your Investment - Purchase payment credits.")

Other information on charges: AEFC makes certain custodial services available to
some  custodial and trusteed  pension and profit  sharing plans and 401(k) plans
funded by our annuities.  Fees for these services start at $30 per calendar year
per  participant.  AEFC will charge a termination fee for owners under age 591/2
(fee waived in case of death or disability).

Possible  group  reductions:  In  some  cases  we  may  incur  lower  sales  and
administrative  expenses due to the size of the group, the average  contribution
and the use of group  enrollment  procedures.  In such cases,  we may be able to
reduce or eliminate the contract administrative and surrender charges.  However,
we expect this to occur infrequently.

<PAGE>

Valuing Your Investment


We value your accounts as follows:


Fixed account
We value the amounts you allocated to the fixed account directly in dollars. The
fixed account value equals:

o    the sum of your  purchase  payments and transfer  amounts  allocated to the
     fixed account;

o    plus any purchase payment credits allocated to the fixed account;

o    plus interest credited;

o    minus the sum of amounts  surrendered  (including any applicable  surrender
     charges) and amounts transferred out; and

o    minus any prorated contract administrative charge.

Subaccounts
We convert amounts you allocated to the  subaccounts  into  accumulation  units.
Each  time you make a  purchase  payment  or  transfer  amounts  into one of the
subaccounts or we apply any purchase payment credits to a subaccount,  we credit
a certain  number of  accumulation  units to your contract for that  subaccount.
Conversely,  each time you take a partial  surrender,  transfer amounts out of a
subaccount, or we assess a contract administrative charge, we subtract a certain
number of accumulation units from your contract.

The  accumulation  units  are the  true  measure  of  investment  value  in each
subaccount during the accumulation period. They are related to, but not the same
as, the net asset value of the fund in which the subaccount invests.  The dollar
value of each accumulation unit can rise or fall daily depending on the variable
account expenses,  performance of the fund and on certain fund expenses. Here is
how we calculate accumulation unit values:


Number of units: to calculate the number of accumulation  units for a particular
subaccount we divide your investment by the current accumulation unit value.

Accumulation unit value: the current accumulation unit value for each subaccount
equals the last value times the subaccount's current net investment factor.


We determine the net investment factor by:

o    adding the fund's  current  net asset  value per share,  plus the per share
     amount of any accrued  income or capital gain dividends to obtain a current
     adjusted net asset value per share; then

o    dividing that sum by the previous adjusted net asset value per share; and

o    subtracting the percentage  factor  representing  the mortality and expense
     risk fee from the result.

Because the net asset value of the fund may  fluctuate,  the  accumulation  unit
value  may  increase  or  decrease.  You  bear  all  the  investment  risk  in a
subaccount.

<PAGE>

Factors that affect subaccount accumulation units: accumulation units may change
in two ways - in number and in value.

The number of accumulation units you own may fluctuate due to:

o        additional purchase payments you allocate to the subaccounts;

o        any purchase payment credits allocated to the subaccounts;

o        transfers into or out of the subaccounts;

o        partial surrenders;

o        surrender charges; and/or

o        prorated portions of the contract administrative charge.

Accumulation unit values will fluctuate due to:

o        changes in funds' net asset value;

o        dividends distributed to the subaccounts;

o        capital gains or losses of funds;

o        fund operating expenses; and/or

o        mortality and expense risk fees.

Purchase payment credits

We add a credit to your  contract in the amount of 1% of each  purchase  payment
received if your initial purchase payment to the contract is at least $100,000.

We fund the credit from our general  account.  We do not consider  credits to be
"investments" for income tax purposes. (See "Taxes.")

We allocate  each credit to your  contract  value when the  applicable  purchase
payment is applied to your  contract  value.  We allocate  such  credits to your
contract value according to allocation  instructions in effect for your purchase
payments.

We will reverse credits from the contract value for any purchase payment that is
not honored.

To the extent a death benefit or surrender  payment  includes  purchase  payment
credits applied within twelve months preceding the date of death that results in
a lump sum death benefit under this contract,  we will assess a charge,  similar
to a surrender charge,  equal to the amount of the purchase payment credits. The
amount we pay to you under these  circumstances will always equal or exceed your
surrender  value.  The amount returned to you under the free look provision also
will not include any credits applied to your contract.


This credit is  available  because of lower costs  associated  with larger sized
contracts  and  lower  compensation  paid on the  sales of these  contracts.  We
reserve  the right to increase  the amount of the credit for  certain  groups of
contract owners. The increase will not be greater than 8% of total net payments.
Increases in credit  amounts are funded by reduced  expenses  expected from such
groups.


<PAGE>

Making the Most of Your Contract

Automated dollar-cost averaging
Currently,  you can use  automated  transfers to take  advantage of  dollar-cost
averaging  (investing a fixed  amount at regular  intervals).  For example,  you
might transfer a set amount monthly from a relatively conservative subaccount to
a more aggressive one, or to several others, or from the fixed account to one or
more subaccounts. There is no charge for dollar-cost averaging.

This systematic  approach can help you benefit from fluctuations in accumulation
unit values caused by fluctuations in the market values of the funds.  Since you
invest the same amount each period,  you  automatically  acquire more units when
the market value falls and fewer units when it rises. The potential effect is to
lower your average cost per unit.

<TABLE>
<CAPTION>
                              How dollar-cost averaging works
<S>                              <C>        <C>           <C>              <C>

                                             Amount       Accumulation        Number of
                                 Month      invested       unit value      units purchased
                              ----------- ------------- ----------------- -------------------

By investing an                   Jan         $100            $20                 5.00
equal number of
dollars each month...             Feb          100             18                 5.56

                                  Mar          100             17                 5.88

you automatically                 Apr          100             15                 6.67
buy more units
when the per unit                 May          100             16                 6.25
market price is low...
                                  Jun          100             18                 5.56

                                  Jul          100             17                 5.88

                                  Aug          100             19                 5.26

and fewer units                  Sept          100             21                 4.76
when the per unit
market price is high.             Oct          100             20                 5.00
</TABLE>

You paid an average price of only $17.91 per unit over the 10 months,  while the
average market price actually was $18.10.

Dollar-cost  averaging does not guarantee that any subaccount will gain in value
nor will it protect  against a decline in value if market  prices fall.  Because
dollar-cost  averaging involves continuous  investing,  your success will depend
upon your  willingness to continue to invest  regularly  through  periods of low
price  levels.  Dollar-cost  averaging can be an effective way to help meet your
long-term goals. For specific features contact your sales representative.

Transferring money between accounts
You may transfer money from any one subaccount, or the fixed account, to another
subaccount  before  annuity  payouts  begin.   (Certain  restrictions  apply  to
transfers  involving  the fixed  account.) We will process your  transfer on the
valuation date we receive your request.  We will value your transfer at the next
accumulation  unit value calculated  after we receive your request.  There is no
charge for transfers.  Before making a transfer,  you should  consider the risks
involved in switching investments.

<PAGE>

Transfer policies


o    Before annuity payouts begin, you may transfer  contract values between the
     subaccounts,  or from the  subaccounts  to the fixed  account  at any time.
     However,  if you made a transfer from the fixed account to the subaccounts,
     you may not make a transfer from any  subaccount  back to the fixed account
     until after 90 days have elapsed.


o    You may transfer  contract values from the fixed account to the subaccounts
     once a year  during a 31-day  transfer  period  starting  on each  contract
     anniversary  (except for  automated  transfers,  which can be set up at any
     time for certain transfer periods subject to certain minimums).

o    If we receive your request  within 30 days before the contract  anniversary
     date,  the  transfer  from the fixed  account  to the  subaccounts  will be
     effective on the anniversary.

o    If we  receive  your  request  on or  within  30 days  after  the  contract
     anniversary  date,  the transfer from the fixed account to the  subaccounts
     will be effective on the valuation date we receive it.

o    We will not accept  requests for  transfers  from the fixed  account at any
     other time.

o    Once annuity payouts begin, you may not make transfers to or from the fixed
     account,  but you may make  transfers  once per  contract  year  among  the
     subaccounts.  During the annuity payout  period,  you cannot invest in more
     than five subaccounts at any one time unless we agree otherwise.

How to request a transfer or surrender

1        By letter

Send  your  name,   contract   number,   Social   Security  Number  or  Taxpayer
Identification Number and signed request for a transfer or surrender to:

Regular mail:
IDS Life Insurance Company of New York
Box 5144
Albany, NY  12205

Express mail:
IDS Life Insurance Company of New York
20 Madison Avenue Extension
Albany, NY  12203

Minimum amount
Transfers or surrenders:   $250 or entire account balance

Maximum amount
Transfers or surrenders:   Contract value or entire account balance

2        By automated transfers and automated partial surrenders

Your sales  representative  can help you set up automated  transfers  among your
subaccounts or fixed account or partial surrenders from the accounts.

<PAGE>

You can start or stop this service by written request or other method acceptable
to us.  You must  allow  30 days  for us to  change  any  instructions  that are
currently in place.

o    Automated  transfers  from the fixed account to any one of the  subaccounts
     may not  exceed an amount  that,  if  continued,  would  deplete  the fixed
     account within 12 months.

o    Automated  surrenders  may be  restricted  by  applicable  law  under  some
     contracts.

o    You  may  not  make  additional  purchase  payments  if  automated  partial
     surrenders are in effect.

o    Automated  partial  surrenders may result in IRS taxes and penalties on all
     or part of the amount surrendered.

Minimum amount
Transfers or surrenders:   $50


Maximum amount
Transfers or surrenders:   None (except for automated transfers from the fixed
                                 account)


Surrenders

You may  surrender  all or part of your  contract  at any  time  before  annuity
payouts  begin by sending us a written  request or calling  us. We will  process
your  surrender  request  on  the  valuation  date  we  receive  it.  For  total
surrenders,  we will compute the value of your contract at the next accumulation
unit value  calculated  after we receive your request.  We may ask you to return
the contract.  You may have to pay  surrender  charges (see "Charges - Surrender
charge") and IRS taxes and penalties (see "Taxes").  You cannot make  surrenders
after annuity  payouts begin except under Plan E (see "The Annuity Payout Period
Annuity payout plans").


Surrender policies
If you have a  balance  in more  than one  account  and you  request  a  partial
surrender,  we will withdraw  money from all your  subaccounts  and/or the fixed
account in the same proportion as your value in each account  correlates to your
total contract value, unless you request otherwise.


Receiving payment By regular or express mail:

o    payable to you;

o    mailed to address of record.

NOTE: We will charge you a fee if you request express mail delivery.

By wire:

o    request that payment be wired to your bank;

o    bank  account  must  be in the  same  ownership  as  your  contract;  and o
     pre-authorization required.


For instructions, contact your sales representative.


<PAGE>

Normally,  we will send the  payment  within  seven  days after  receiving  your
request. However, we may postpone the payment if:

    - the  surrender  amount  includes  a purchase  payment  check that has not
      cleared;
    - the NYSE is  closed,  except  for normal  holiday  and  weekend closings;
    - trading on the NYSE is restricted, according to SEC rules;
    - an emergency, as defined by SEC rules, makes it impractical to sell
      securities or value the net assets of the accounts;
    - the SEC  permits  us to delay  payment  for the  protection  of  security
      holders;  or


    - and to the extent  permitted  or required  under the Federal Investment
      Company Act of 1940, as amended, and any other applicable federal or state
      law.


TSA -- Special Surrender Provisions

Participants in Tax-Sheltered Annuities
The  Code  imposes   certain   restrictions  on  your  right  to  receive  early
distributions from a TSA:

o    Distributions   attributable  to  salary  reduction   contributions   (plus
     earnings) made after Dec. 31, 1988, or to transfers or rollovers from other
     contracts, may be made from the TSA only if:

     -- you are at least age 59 1/2;
     -- you are disabled as defined in the Code;
     -- you  separated  from the  service  of the  employer  who  purchased  the
        contract; or
     -- the distribution is because of your death.

o    If you  encounter a financial  hardship  (as defined by the Code),  you may
     receive  a  distribution  of all  contract  values  attributable  to salary
     reduction  contributions  made after Dec. 31, 1988, but not the earnings on
     them.

o    Even though a distribution  may be permitted  under the above rules, it may
     be subject to IRS taxes and penalties (see "Taxes").

o    The employer must comply with certain  nondiscrimination  requirements  for
     certain  types of  contributions  under a TSA contract to be excluded  from
     taxable income.  You should consult your employer to determine  whether the
     nondiscrimination rules apply to you.

o    The above  restrictions on  distributions do not affect the availability of
     the amount  credited to the contract as of Dec. 31, 1988. The  restrictions
     also do not apply to transfers  or  exchanges of contract  value within the
     contract,  or to another registered variable annuity contract or investment
     vehicle available through the employer.

o    If the  contract  has a loan  provision,  the  right to  receive  a loan as
     described in detail in your contract.

Changing Ownership

You may change ownership of your nonqualified  annuity at any time by completing
a change of ownership  form we approve and sending it to our office.  The change
will  become  binding  upon us when we receive  and record it. We will honor any
change  of  ownership  request  that we  believe  is  authentic  and we will use
reasonable procedures to confirm authenticity. If we follow these procedures, we
will not take any responsibility for the validity of the change.

If you have a  nonqualified  annuity,  you may incur  income  tax  liability  by
transferring, assigning or pledging any part of it. (See "Taxes.")

<PAGE>

If you have a qualified annuity, you may not sell, assign, transfer, discount or
pledge  your  contract  as  collateral  for a  loan,  or  as  security  for  the
performance  of an  obligation  or for any other  purpose  except as required or
permitted  by the Code.  However,  if the owner is a trust or  custodian,  or an
employer  acting  in a  similar  capacity,  ownership  of  the  contract  may be
transferred to the annuitant.

Benefits in Case of Death

We will pay the death benefit to your beneficiary upon the earlier of your death
or the  annuitant's  death. If a contract has more than one person as the owner,
we will pay benefits upon the first to die of any owner or the annuitant.

If you or the annuitant die before annuity  payouts begin while this contract is
in force, we will pay the beneficiary as follows:

If both you and the  annuitant  are age 80 or younger on the date of death,  the
beneficiary receives the greatest of:

o    the contract value;

o    purchase payments, minus any "adjusted partial surrenders"; or

o    the contract value as of the most recent sixth contract  anniversary,  plus
     any purchase  payments  paid and minus any  "adjusted  partial  surrenders"
     since that anniversary.

If either  you or the  annuitant  are age 81 or older on the date of death,  the
beneficiary receives the greater of:

o    the contract value; or

o    purchase payments minus any "adjusted partial surrenders."

Adjusted partial  surrenders:  We calculate an "adjusted partial  surrender" for
each partial surrender as the product of (a) times (b) where

                  (a) is  the  ratio  of the  amount  of the  partial  surrender
                  (including  any applicable  surrender  charge) to the contract
                  value on the date of (but prior to) the partial surrender; and

                  (b) is the  death  benefit  on the date of (but  prior to) the
                  partial surrender.

Example of death benefit  calculation when the owner and annuitant are age 80 or
younger:

o    You purchase the contract with a payment of $20,000 on Jan. 1, 2001.

o    On Jan 1, 2007 (the 6th contract  anniversary)  the contract value grows to
     $30,000.

o    March 1, 2007 the contract value falls to $28,000 at which point you take a
     $1,500 partial surrender, leaving a contract value of $26,500.


<PAGE>


We calculate the death benefit on March 1, 2007 as follows:


The contract value on the most recent 6th contract anniversary:       $30,000.00
plus any purchase payments paid since that anniversary:               +     0.00
minus any "adjusted partial surrenders" taken since that anniversary
calculated as:           $1,500  x  $30,000    =
                                            $28,000                 -   1,607.14
                                                                    ------------
for a death benefit of:                                              $ 28,392.86

If your  spouse is sole  beneficiary  under a  nonqualified  annuity and you die
before the settlement  date,  your spouse may keep the contract as owner.  To do
this your spouse must,  within 60 days after we receive proof of death,  give us
written instructions to keep the contract in force.

Under a  qualified  annuity,  if the  annuitant  dies  before the Code  requires
distributions to begin, and the spouse is the only  beneficiary,  the spouse may
keep the  contract  as owner  until the date on which the  annuitant  would have
reached  age 70 1/2 or any other date  permitted  by the Code.  To do this,  the
spouse must give us written  instructions  within 60 days after we receive proof
of death.

Payments:  Under a nonqualified  annuity we will pay the beneficiary in a single
sum unless you give us other  written  instructions.  A death  benefit paid in a
single sum will be reduced by the amount of any purchase payment credits applied
to the  contract  within  12 months of the date of  death.  (See  "Valuing  Your
Investment - Purchase  Payment  credits.")  We must fully  distribute  the death
benefit within five years of your death.  However,  the  beneficiary may receive
payouts under any annuity payout plan available under this contract if:

o    the beneficiary asks us in writing within 60 days after we receive proof of
     death;  and

o    payouts  begin no later than one year after  your  death,  or other date as
     permitted by the Code; and

o    the payout  period does not extend  beyond the  beneficiary's  life or life
     expectancy.

When paying the  beneficiary,  we will process the death claim on the  valuation
date  our  death  claim  requirements  are  fulfilled.  We  will  determine  the
contract's value at the next  accumulation unit value calculated after our death
claim  requirements  are  fulfilled.  We pay interest,  if any, from the date of
death at a rate no less  than  required  by law.  We will  mail  payment  to the
beneficiary within seven days after our death claim requirements are fulfilled.

Other rules may apply to qualified annuities. (See "Taxes.")

The Annuity Payout Period


As owner of the  contract,  you have the right to decide how and to whom annuity
payouts will be made starting at the settlement  date. You may select one of the
annuity  payout plans outlined  below,  or we may mutually agree on other payout
arrangements.  We do not deduct any  surrender  charges  under the payout  plans
listed below.


You also  decide  whether we will make  annuity  payouts on a fixed or  variable
basis, or a combination of fixed and variable. The amounts available to purchase
payouts under the plan you select is the contract value on your settlement date.
You may  reallocate  this  contract  value to the fixed account to provide fixed
dollar payouts and/or among the subaccounts to provide variable annuity payouts.
During  the  annuity  payout  period,  you  cannot  invest  in  more  than  five
subaccounts at any one time unless we agree otherwise.

<PAGE>

Amounts of fixed and variable payouts depend on:

o        the annuity payout plan you select;

o        the annuitant's age and, in most cases, sex;

o        the annuity table in the contract; and

o        the amounts you allocated to the accounts at settlement.

In  addition,  for  variable  payouts  only,  amounts  depend on the  investment
performance of the subaccounts you select. These payouts will vary from month to
month because the performance of the funds will fluctuate. (In the case of fixed
annuities, payouts remain the same from month to month.)

For information with respect to transfers between accounts after annuity payouts
begin, see "Making the Most of Your Contract -- Transfer policies."

Annuity table
The annuity table in your contract shows the amount of the first monthly payment
for each $1,000 of contract value according to the age and, when applicable, the
sex of the  annuitant.  (Where  required by law,  we will use a unisex  table of
settlement  rates.) The table assumes that the contract value is invested at the
beginning of the annuity  payout period and earns a 5% rate of return,  which is
reinvested and helps to support future payouts.

Substitution of 3.5% table
If you ask us at least 30 days before the retirement date, we will substitute an
annuity table based on an assumed 3.5%  investment  rate for the 5% table in the
contract.  The  assumed  investment  rate  affects  both the amount of the first
payout and the extent to which subsequent  payouts  increase or decrease.  Using
the 5% table  results  in a higher  initial  payment,  but  later  payouts  will
increase  more slowly when annuity  unit values rise and  decrease  more rapidly
when they decline.

Annuity payout plans
You may  choose  any one of these  annuity  payout  plans by giving  us  written
instructions  at least 30 days before  contract  values are used to purchase the
payout plan:

o    Plan A - Life  annuity  - no  refund:  We make  monthly  payouts  until the
     annuitant's death.  Payouts end with the last payout before the annuitant's
     death.  We will  not make  any  further  payouts.  This  means  that if the
     annuitant dies after we made only one monthly payout,  we will not make any
     more payouts.

o    Plan B - Life annuity with five, ten or 15 years  certain:  We make monthly
     payouts for a guaranteed  payout  period of five,  ten or 15 years that you
     elect.  This election will determine the length of the payout period to the
     beneficiary if the annuitant  should die before the elected period expires.
     We calculate the guaranteed  payout period from the settlement date. If the
     annuitant  outlives the elected  guaranteed payout period, we will continue
     to make payouts until the annuitant's death.

o    Plan C - Life annuity - installment  refund:  We make monthly payouts until
     the  annuitant's  death,  with our guarantee that payouts will continue for
     some period of time. We will make payouts for at least the number of months
     determined  by dividing the amount  applied  under this option by the first
     monthly payout, whether or not the annuitant is living.

o    Plan D - Joint and last survivor life annuity - no refund:  We make monthly
     payouts  while both the  annuitant  and a joint  annuitant  are living.  If
     either annuitant dies, we will continue to make monthly payouts at the full
     amount  until the death of the  surviving  annuitant.  Payouts end with the
     death of the second annuitant.
<PAGE>


o    Plan E - Payouts  for a specified  period:  We make  monthly  payouts for a
     specific  payout  period of ten to 30 years  that you  elect.  We will make
     payouts  only for the number of years  specified  whether the  annuitant is
     living or not.  Depending on the selected  time period,  it is  foreseeable
     that an annuitant can outlive the payout period selected. During the payout
     period,  you can  elect  to have us  determine  the  present  value  of any
     remaining  variable  payouts and pay it to you in a lump sum. We  determine
     the present  value of the  remaining  annuity  payouts which are assumed to
     remain level at the initial payment. For qualified contracts,  the discount
     rate we use in the calculation will vary between 4.72% and 6.22%, depending
     on the applicable assumed investment rate. For nonqualified contracts,  the
     discount rate we use in the calculation  will vary between 4.92% and 6.42%,
     depending  on the  applicable  assumed  investment  rate.  (See  "Charges -
     Surrender charge under Annuity Payout Plan E.") You can also take a portion
     of the  discounted  value once a year.  If you do so, your monthly  payouts
     will be reduced by the proportion of your surrender to the full  discounted
     value.  A 10% IRS  penalty tax could  apply if you take a  surrender.  (See
     "Taxes.")

Restrictions  for  some  tax-deferred  retirement  plans:  If  you  purchased  a
qualified annuity, you may be required to select a payout plan that provides for
payouts:


o    over the life of the annuitant;

o    over the joint lives of the annuitant and a designated beneficiary;

o    for a period not exceeding the life expectancy of the annuitant; or

o    for a period not exceeding the joint life expectancies of the annuitant and
     a designated beneficiary.

You have the  responsibility  for electing a payout plan that complies with your
contract and with applicable law.

If we do not receive instructions: You must give us written instructions for the
annuity payouts at least 30 days before the annuitant's  retirement date. If you
do not, we will make payouts under Plan B, with 120 monthly payouts  guaranteed.
Contract  values that you  allocated to the fixed  account  will  provide  fixed
dollar payouts and contract values that you allocated among the subaccounts will
provide variable annuity payouts.

If  monthly  payouts  would be less than $20:  We will  calculate  the amount of
monthly  payouts  at the time the  contract  value is used to  purchase a payout
plan. If the  calculations  show that monthly payouts would be less than $20, we
have the right to pay the contract value to the owner in a lump sum or to change
the frequency of the payouts.

Death after annuity payouts begin
If you or the annuitant die after annuity  payouts begin, we will pay any amount
payable to the beneficiary as provided in the annuity payout plan in effect.

Taxes

Generally,  under current law, your  contract has a tax deferral  feature.  This
means,  any increase in the value of the fixed  account  and/or  subaccounts  in
which you invest is taxable to you only when you  receive a payout or  surrender
(see  detailed  discussion  below).  Any portion of the annuity  payouts and any
surrenders you request that represent  ordinary income are normally taxable.  We
will send you a tax  information  reporting form for any year in which we made a
taxable  distribution  according  to our  records.  Roth  IRAs  may  grow and be
distributed tax-free if you meet certain distribution requirements.

<PAGE>

Annuity payouts under nonqualified  annuities:  A portion of each payout will be
ordinary  income  and  subject  to tax,  and a portion  of each  payout  will be
considered  a return  of part of your  investment  and will  not be  taxed.  All
amounts you receive  after your  investment  in the contract is fully  recovered
will be subject to tax.

Tax law requires that all  nonqualified  deferred  annuities  issued by the same
company (and possibly its  affiliates)  to the same owner during a calendar year
be taxed as a single,  unified contract when you take distributions from any one
of those contracts.

Qualified annuities: Your contract may be used to fund a tax-deferred retirement
plan that is already  tax-deferred under the Code. The contract will not provide
any necessary or additional tax deferral if it is used to fund a retirement plan
that is tax deferred. Special rules apply to these retirement plans. Your rights
to benefits may be subject to the terms and conditions of these retirement plans
regardless of the terms of the contract.

Adverse tax  consequences  may result if you do not ensure  that  contributions,
distributions  and other  transactions  under the contract  comply with the law.
Qualified  annuities have minimum  distribution rules that govern the timing and
amount of  distributions  during your life (except for Roth IRAs) and after your
death. You should refer to your retirement plan or adoption agreement or consult
a tax advisor for more information about your distribution rules.


Annuity payouts under qualified  annuities (except Roth IRAs): Under a qualified
annuity,  the entire payout  generally is  includable as ordinary  income and is
subject to tax except to the extent that  contributions were made with after-tax
dollars.  If you or your employer  invested in your contract with  deductible or
pre-tax dollars as part of a tax-deferred  retirement plan, such amounts are not
considered to be part of your  investment in the contract and will be taxed when
paid to you.

Purchase  payment  credits:   These  are  considered   earnings  and  are  taxed
accordingly.


Surrenders:  If you surrender  part or all of your contract  before your annuity
payouts begin, your surrender payment will be taxed to the extent that the value
of your contract  immediately before the surrender exceeds your investment.  You
also may have to pay a 10% IRS penalty for surrenders  you make before  reaching
age 59 1/2 unless  certain  exceptions  apply.  For qualified  annuities,  other
penalties may apply if you surrender  your contract  before your plan  specifies
that you can receive payouts.


Death benefits to  beneficiaries:  The death benefit under a contract  (except a
Roth  IRA)  is  not  tax-exempt.  Any  amount  your  beneficiary  receives  that
represents  previously  deferred  earnings  within  the  contract  is taxable as
ordinary income to the beneficiary in the years he or she receives the payments.
The death benefit  under a Roth IRA generally is not taxable as ordinary  income
to the beneficiary if certain distribution requirements are met.


Annuities  owned by  corporations,  partnerships  or  trusts:  For  nonqualified
annuities  any annual  increase in the value of annuities  held by such entities
generally will be treated as ordinary  income  received  during that year.  This
provision is effective for purchase payments made after Feb. 28, 1986.  However,
if the trust was set up for the  benefit of a natural  person  only,  the income
will remain tax-deferred.

<PAGE>


Penalties: If you receive amounts from your contract before reaching age 59 1/2,
you may have to pay a 10% IRS penalty on the amount  includable in your ordinary
income.  If you receive amounts from your SIMPLE IRA before reaching age 59 1/2,
generally  the IRS penalty  provisions  apply.  However,  if you  receive  these
amounts before age 59 1/2, and within the first two years of your  participation
in the  SIMPLE  IRA plan,  the IRS  penalty  will be  assessed  at a rate of 25%
instead of 10%.  However,  this penalty will not apply to any amount received by
you or your beneficiary:


o    because of your death;

o    because you become disabled (as defined in the Code);

o    if the  distribution  is part of a series of  substantially  equal periodic
     payments,  made at least  annually,  over your life or life  expectancy (or
     joint lives or life expectancies of you and your beneficiary); or

o    if it is  allocable  to an  investment  before Aug.  14,  1982  (except for
     qualified annuities).

For a  qualified  annuity,  other  penalties  or  exceptions  may  apply  if you
surrender your contract before your plan specifies that payouts can be made.


Withholding, generally: If you receive all or part of the contract value, we may
deduct  withholding  against  the taxable  income  portion of the  payment.  Any
withholding  represents  a  prepayment  of your tax due for the  year.  You take
credit for these amounts on your annual tax return.


If the  payment is part of an annuity  payout  plan,  we  generally  compute the
amount of withholding using payroll tables.  You may provide us with a statement
of how many exemptions to use in calculating the withholding.  As long as you've
provided  us with a valid  Social  Security  Number or  Taxpayer  Identification
Number, you can elect not to have any withholding occur.

If the  distribution  is any other  type of  payment  (such as a partial or full
surrender),  we compute withholding using 10% of the taxable portion. Similar to
above,  as long as you have provided us with a valid Social  Security  Number or
Taxpayer  Identification  Number,  you can elect  not to have  this  withholding
occur.

Some  states  also  impose  withholding  requirements  similar  to  the  federal
withholding  described  above.  If this should be the case,  we may deduct state
withholding  from any  payment  from which we deduct  federal  withholding.  The
withholding  requirements  may  differ if we are  making  payment  to a non-U.S.
citizen or if we deliver the payment outside the United States.

Withholding from qualified annuities: If you receive directly all or part of the
contract value from a qualified  annuity (except an IRA, Roth IRA, SIMPLE IRA or
SEP),  mandatory 20% federal income tax  withholding  (and possibly state income
tax  withholding)  generally  will be imposed at the time we make  payout.  This
mandatory  withholding is in place of the elective withholding  discussed above.
This mandatory withholding will not be imposed if:

o    instead  of  receiving  the  distribution  check,  you  elect  to have  the
     distribution rolled over directly to an IRA or another eligible plan;

o    the payout is one in a series of substantially equal periodic payouts, made
     at least annually, over your life or life expectancy (or the joint lives or
     life  expectancies  of you  and  your  designated  beneficiary)  or  over a
     specified period of 10 years or more; or

o    the payout is a minimum distribution required under the Code.

Payments we make to a surviving  spouse instead of being directly rolled over to
an IRA also may be subject to mandatory 20% income tax withholding.

State withholding also may be imposed on taxable distributions.

<PAGE>

Transfer of ownership of a nonqualified  annuity: If you transfer a nonqualified
annuity without  receiving  adequate  consideration,  the transfer is a gift and
also may be a  surrender  for  federal  income  tax  purposes.  If the gift is a
currently  taxable  event for income tax  purposes,  the original  owner will be
taxed on the amount of deferred  earnings at the time of the  transfer  and also
may be subject to the 10% IRS penalty discussed  earlier.  In this case, the new
owner's investment in the contract will be the value of the contract at the time
of the transfer.

Collateral  assignment of a nonqualified  annuity: If you collaterally assign or
pledge your contract, earnings on purchase payments you made after Aug. 13, 1982
will be taxed to you like a surrender.

Important: Our discussion of federal tax laws is based upon our understanding of
current   interpretations   of  these   laws.   Federal   tax  laws  or  current
interpretations of them may change. For this reason and because tax consequences
are complex and highly  individual and cannot always be anticipated,  you should
consult a tax advisor if you have any questions about taxation of your contract.

Tax qualification: We intend that the contract qualify as an annuity for federal
income tax  purposes.  To that end,  the  provisions  of the  contract are to be
interpreted to ensure or maintain such tax qualification,  in spite of any other
provisions  of the  contract.  We  reserve  the right to amend the  contract  to
reflect any  clarifications  that may be needed or are  appropriate  to maintain
such  qualification or to conform the contract to any applicable  changes in the
tax qualification requirements. We will send you a copy of any amendments.

Voting Rights

As a  contract  owner  with  investments  in the  subaccounts,  you may  vote on
important fund policies until annuity payouts begin. Once they begin, the person
receiving  them has voting  rights.  We will vote fund shares  according  to the
instructions of the person with voting rights.

Before  annuity  payouts  begin,  the number of votes you have is  determined by
applying  your  percentage  interest in each  subaccount  to the total number of
votes allowed to the subaccount.

After annuity payouts begin, the number of votes you have is equal to:

o the reserve held in each  subaccount for your  contract;  divided by

o the net asset value of one share of the applicable fund.

As we make annuity payouts,  the reserve for the contract decreases;  therefore,
the number of votes also will decrease.

We  calculate  votes  separately  for each  subaccount.  We will send  notice of
shareholders'  meetings,  proxy materials and a statement of the number of votes
to which  the  voter is  entitled.  We will  vote  shares  for which we have not
received  instructions in the same proportion as the votes for which we received
instructions.  We also will vote the shares for which we have  voting  rights in
the same proportion as the votes for which we received instructions.

Substitution of Investments

We may substitute the funds in which the subaccounts invest if:

   o    laws or regulations change;

   o    the existing funds become unavailable; or

   o    in our judgment, the funds no longer are suitable for the subaccounts.

<PAGE>

If any of these  situations  occur, and if we believe it is in the best interest
of  persons  having  voting  rights  under  the  contract,  we have the right to
substitute the funds currently listed in this prospectus for other funds.

We   may also:

o    add new subaccounts;

o    combine any two or more subaccounts;

o    make  additional  subaccounts  investing in  additional  funds;

o    transfer assets to and from the subaccounts or the variable account; and

o    eliminate or close any subaccounts.

In the event of substitution or any of these changes,  we may amend the contract
and take whatever  action is necessary and  appropriate  without your consent or
approval.  However,  we will not make any  substitution  or change  without  the
necessary  approval of the SEC and state insurance  departments.  We will notify
you of any substitution or change.

About the Service Providers

Principal underwriter
American Express Financial Advisors Inc. (AEFA) is the principal underwriter for
the contract. Its offices are located at 200 AXP Financial Center,  Minneapolis,
MN 55474.  AEFA is a  wholly-owned  subsidiary  of  American  Express  Financial
Corporation  (AEFC)  which is a  wholly-owned  subsidiary  of  American  Express
Company, a financial services company headquartered in New York City.


The AEFC family of companies  offers not only insurance and annuities,  but also
mutual funds, investment certificates, and a broad range of financial management
services.  AEFA serves individuals and businesses through its nationwide network
of more than _____ supervisory offices,  more than ____ branch offices and _____
financial advisors.


Issuer
IDS  Life  of  New  York  issues  the  contracts.  IDS  Life  of New  York  is a
wholly-owned subsidiary of IDS Life, which is a wholly-owned subsidiary of AEFC.


IDS Life of New York is a stock life insurance  company  organized in 1972 under
the laws of the State of New York and is located at 20 Madison Avenue Extension,
Albany,  New York 12203. Its mailing address is P.O. Box 5144, Albany, NY 12205.
IDS Life of New York conducts a conventional life insurance business.


IDS Life of New York pays  commissions for sales of the contracts of up to 7% of
the  total  purchase  payments  it  receives.  This  revenue  is used  to  cover
distribution  costs that include  compensation to advisors and field  leadership
for the selling advisors.  These commissions consist of a combination of time of
sale and on-going  service/trail  commissions (which, when totaled, could exceed
7% of purchase  payments).  From time to time,  IDS Life of New York will pay or
permit other promotional incentives, in cash or credit or other compensation.

<PAGE>

Legal proceedings
A number of  lawsuits  have been  filed  against  life and  health  insurers  in
jurisdictions  in which  IDS Life of New York  and its  affiliates  do  business
involving  insurers'  sales  practices,  alleged  agent  misconduct,  failure to
properly supervise agents,  and other matters.  IDS Life is a defendant in three
class action lawsuits of this nature.  IDS Life of New York is a named defendant
in one of these suits, Richard W. and Elizabeth J. Thoresen vs. American Express
Financial  Corporation,  American  Centurion  Life Assurance  Company,  American
Enterprise Life Insurance Company, American Partners Life Insurance Company, IDS
Life  Insurance  Company  and IDS Life  Insurance  Company of New York which was
commenced in Minnesota  State Court in October  1998.  The action was brought by
individuals who purchased an annuity in a qualified plan. The plaintiffs  allege
that the sale of annuities in tax-deferred  contributory  retirement  investment
plans (e.g., IRAs) is never  appropriate.  The plaintiffs purport to represent a
class consisting of all persons who made similar purchases.  The plaintiffs seek
damages in an unspecified amount.


IDS Life of New York is included  as a party to  preliminary  settlement  of all
three class  action  lawsuits.  We believe  this  approach  will put these cases
behind us and provide a fair  outcome for our  clients.  Our  decision to settle
does not include any admission of  wrongdoing.  We do not  anticipate  that this
proposed  settlement,  or any other  lawsuits in which IDS Life of New York is a
defendant, will have a material adverse effect on our financial condition.


Year 2000

The Year 2000 issue is the result of computer programs having been written using
two  digits  rather  than  four  to  define  a  year.  Any  programs  that  have
time-sensitive  software may recognize a date using "00" as the year 1900 rather
than 2000. This could result in the failure of major systems or miscalculations,
which could have a material impact on the operations of IDS Life of New York and
the variable accounts. All of the major systems used by IDS Life of New York and
the  variable  accounts  are  maintained  by AEFC and are  utilized  by multiple
subsidiaries  and  affiliates  of AEFC.  IDS Life of New York's and the variable
accounts' businesses are heavily dependent upon AEFC's computer systems and have
significant interaction with systems of third parties.


A  comprehensive  review of AEFC's  computer  systems  and  business  processes,
including those specific to IDS Life of New York and the variable accounts,  was
conducted to identify the major  systems that could be affected by the Year 2000
issue. Steps were taken to resolve potential problems including  modification to
existing  software and the purchase of new software.  As of Dec. 31, 1999,  AEFC
had  completed its program of  corrective  measures on its internal  systems and
applications,  including Year 2000 compliance testing. As of Dec. 31, 1999, AEFC
had also  completed  an  evaluation  of the Year 2000  readiness  of other third
parties whose system failures could have an impact on IDS Life of New York's and
the variable accounts' operations.

AEFC's Year 2000 project also included  establishing Year 2000 contingency plans
for all key business units.  Business continuation plans, which address business
continuation  in the  event of a  system  disruption,  are in place  for all key
business  units.  At Dec.  31,  1999,  these  plans had been  amended to include
specific Year 2000 considerations.

In  assessing  its Year 2000  initiatives  and the results of actual  production
since Jan. 1, 2000,  management  believes no material adverse  consequences were
experienced,  and there was no material effect on IDS Life of New York's and the
variable accounts' business,  results of operations, or financial condition as a
result of the Year 2000 issue.


<PAGE>

Table of Contents of the Statement of Additional Information


Performance Information......................................3
Calculating Annuity Payouts.................................13
Rating Agencies.............................................15
Principal Underwriter.......................................15
Independent Auditors........................................15
Financial Statements


<PAGE>

Please  check  the  appropriate  box to  receive  a copy  of  the  Statement  of
Additional Information for:

[  ] American Express Retirement Advisor Variable AnnuitySM
[  ] American Express Variable Portfolio Funds
[  ] AIM Variable Insurance Funds, Inc.
[  ] American Century Variable Portfolios, Inc.
[  ] Calvert Variable Series, Inc.
[  ] Fidelity Variable Insurance Products Funds - Service Class
[  ] Franklin Templeton Variable Insurance Products Trust - Class 2
[  ] Goldman Sachs Variable Insurance Trust (VIT)
[  ] Janus Aspen Series: Service Shares
[  ] Lazard Retirement Series, Inc.
[  ] MFS(R) Variable Insurance Trust SM
[  ] Putnam Variable Trust
[  ] Royce Capital Fund
[  ] Third Avenue Variable Series Trust
[  ] Wanger Advisors Trust
[  ] Warburg Pincus Trust - Emerging Growth Portfolio

Mail your request to:

IDS Life of New York Annuity Service
IDS Life Insurance Company of New York
Box 5144
Albany, NY  12205

We will mail your request to:

Your name_______________________________________________________________________

Address_________________________________________________________________________

City________________________________________ State_______________ Zip___________

<PAGE>

                       STATEMENT OF ADDITIONAL INFORMATION

                                       for

                 AMERICAN EXPRESS RETIREMENT ADVISOR VARIABLE ANNUITYSM

                  IDS Life of New York Variable Annuity Account


                                    __________, 2000


IDS Life of New York Variable Annuity Account is a separate account  established
and maintained by IDS Life Insurance Company of New York (IDS Life of New York).

This Statement of Additional Information (SAI) is not a prospectus. It should be
read together with the prospectus  dated the same date as this SAI, which may be
obtained by writing or calling us at the address and telephone number below. The
prospectus is incorporated in this SAI by reference.


IDS Life Insurance Company of New York
20 Madison Avenue Extension
Albany, NY  12203
800-541-2251

<PAGE>

American Express Retirement Advisor Variable Annuity
IDS Life of New York Variable Annuity Account

                                TABLE OF CONTENTS

Performance Information...................................p. 3

Calculating Annuity Payouts.............................. p. 13

Rating Agencies...........................................p. 15

Principal Underwriter.....................................p. 15

Independent Auditors......................................p. 15

Financial Statements

<PAGE>

PERFORMANCE INFORMATION

The  subaccounts  may quote  various  performance  figures  to  illustrate  past
performance.  We base total return and current yield  quotations (if applicable)
on standardized  methods of computing  performance as required by the Securities
and Exchange  Commission  (SEC).  An  explanation of the methods used to compute
performance follows below.

Average Annual Total Return

We will express quotations of average annual total return for the subaccounts in
terms  of the  average  annual  compounded  rate  of  return  of a  hypothetical
investment  in the  contract  over a period of one,  five and ten years (or,  if
less, up to the life of the subaccounts),  calculated according to the following
formula:

                                  P(1+T)n = ERV

where:         P =  a hypothetical initial payment of $1,000
               T =  average annual total return
               n =  number of years
             ERV =  Ending  Redeemable Value of a hypothetical  $1,000 payment
                    made  at the  beginning  of the  period,  at the  end of the
                    period (or fractional portion thereof)

We  calculated  the  following  performance  figures on the basis of  historical
performance of each fund.  Currently we do not show any performance  information
for the subaccounts  because they are new and have not had any activity to date.
However,  we show performance from the commencement  date of the funds as if the
contract  existed  at that time,  which it did not.  Past  performance  does not
guarantee future results.

<PAGE>

Average Annual Total Return For Nonqualified Annuities (Without Purchase Payment
Credits) Without a Surrender For Periods Ending Dec. 31, 1999

<TABLE>
<CAPTION>


                                                                    Performance Since Commencement of the
                                                                                    Fund*
<S>          <C>                                                  <C>      <C>      <C>       <C>
                                                                                                  Since
Subaccount   Investing In:                                         1 Year  5 Years  10 Years  Commencement
----------   -------------                                         ------  -------  --------  ------------
             AXPSM VARIABLE PORTFOLIO -
   BC7             Blue Chip Advantage Fund (9/99)**                  --%      --%      --%       10.98%
   BD7             Bond Fund (10/81)                                0.69     6.93     7.10         9.62
   CR7             Capital Resource Fund (10/81)                   22.52    20.15    14.36        14.83
   CM7             Cash Management Fund (10/81)                     3.68     4.07     3.86         5.52
   DE7             Diversified Equity Income Fund (9/99)             --       --       --          2.53
   EM7             Emerging Markets Fund (5/00)+                     --       --       --          --
   EI7             Extra Income Fund (5/96)                         5.18      --       --          4.46
   FI7             Federal Income Fund (9/99)                        --       --       --          0.30
   GB7             Global Bond Fund (5/96)                         -5.37      --       --          3.03
   GR7             Growth Fund (9/99)                                --       --       --         17.89
   IE7             International Fund (1/92)                       44.19    14.99      --         12.25
   MF7             Managed Fund (4/86)                             13.70    17.05    12.41        11.76
   ND7             New Dimensions Fund(R)(5/96)                     30.70      --       --         25.10
   IV7             S&P 500 Index Fund (5/00)+                        --       --       --          --
   SC7             Small Cap Advantage Fund (9/99)                   --       --       --         12.35
   SA7             Strategy Aggressive Fund (1/92)                 69.36    23.56      --         15.86
             AIM V.I.
   7CA             Capital Appreciation Fund (5/93)                43.21    24.34      --         21.11
   7CD             Capital Development Fund (5/98)                 27.82      --       --         10.09
             American Century VARIABLE PORTFOLIOS, INC.
   7IF             VP International (5/94)                         62.44    20.97      --         17.07
   7VA             VP Value (5/96)                                 -1.84      --       --          9.99
             CALVERT CVS
   7SR             Social Balanced Portfolio (9/86)                11.13   15.73    11.22         14.68
             FIDELITY VIP
   7GI             III Growth & Income Portfolio (Service Class)    6.62      --       --         19.63
                   (12/96)
   7MP             III Mid Cap Portfolio (Service Class) (12/98)   47.28      --       --         51.32
   7OS             Overseas Portfolio (Service Class) (12/87)      40.99    16.16    10.29        11.29
             FRANKLIN TEMPLETON VIP TRUST
   7RE             Franklin Real Estate Fund - Class 2 (1/89)***   -7.62     6.45     7.59         7.28
   7SI             Franklin Value Securities Fund - Class 2         0.38      --       --        -14.08
                   (5/98)***
   7IS             Templeton International Smaller Companies       22.70      --       --          4.20
                   Fund - Class 2 (5/96)***
             GOLDMAN SACHS VIT
   7SE             CORESM Small Cap Equity Fund (2/98)****         16.37      --       --          2.37
   7UE             CORESM U.S. Equity Fund (2/98)                  23.07      --       --         19.53
   7MC             Mid Cap Value Fund (4/98)                       -1.95      --       --         -9.80
             JANUS ASPEN SERIES
   7AG             Aggressive Growth Portfolio - Service Shares    121.13   34.52      --         32.68
                   (9/93)
   7GT             Global Technology Portfolio - Service Shares      --       --       --          --
                   (1/00) +
   7IG             International Growth Portfolio - Service        77.84    31.99      --         27.28
                   Shares (4/94)
             LAZARD RETIREMENT SERIES
   7IP             International Equity Portfolio (9/98)           20.21      --       --         24.97
             MFS(R) VARIABLE INSURANCE TRUST (VIT)
   7MG             Growth Series - Service Class (5/99)              --       --       --         51.04
   7MD             New Discovery Series - Service Class (5/98)     92.33      --       --         40.64

<PAGE>

             PUTNAM VARIABLE TRUST
   7IN             Putnam VT International New Opportunities       100.85     --       --         50.24
                   Fund - Class IB Shares (4/98)*****
   7VS             Putnam VT Vista Fund - Class IB Shares          51.18      --       --         29.77
                   (1/97)*****
             ROYCE CAPITAL FUND
   7MI             Micro-Cap Portfolio (12/96)                     26.85      --       --         16.16
             THIRD AVENUE
   7SV             Value Portfolio (9/99)                            --       --       --         8.06
             WANGER
   7IT             International Small Cap (5/95)                  124.28     --       --         37.40
   7SP             U.S. Small Cap (5/95)                           23.66      --       --         25.20
             WARBURG PINCUS TRUST
   7EG             Emerging Growth Portfolio  (9/99)                 --       --       --         34.51
</TABLE>

*Current  applicable  charges  deducted  from  fund  performance  include  a $30
contract administrative charge and a 0.95% mortality and expense risk fee.

+ Fund had not commenced operations as of Dec. 31, 1999.

**(Commencement date of the Funds)

***Because no Class 2 Shares were issued until Jan. 6, 1999, Class 2 performance
represents  the  historical  results of Class 1 Shares.  Performance  of Class 2
Shares for periods  after its January 6, 1999  inception  will reflect Class 2's
additional  12b-1  fee  expense  which  also  affects  all  future  performance.

****CoreSM  is a service  mark of Goldman,  Sachs & Co.  ***** Each of the above
Funds' Class IB Shares commenced operations on April 30, 1998. For periods prior
to inception of Class IB Shares,  performance information for Class IB Shares is
based upon performance of Class IA Shares (not offered) of the fund, adjusted to
reflect the fees paid by Class IB Shares, including the 12b-1 fee of 0.15%.

<PAGE>


Average Annual Total Return For Nonqualified Annuities (Without Purchase Payment
Credits) With a Surrender For Periods Ending Dec. 31, 1999


<TABLE>
<CAPTION>
                                                                    Performance Since Commencement of the
                                                                                    Fund*

<S>          <C>                                                   <C>     <C>      <C>       <C>

                                                                                                  Since
Subaccount   Investing In:                                         1 Year  5 Years  10 Years  Commencement
----------   -------------                                         ------  -------  --------  ------------
             AXPSM VARIABLE PORTFOLIO -
   BC7             Blue Chip Advantage Fund (9/99)**                --%      --%      --%         3.98%
   BD7             Bond Fund (10/81)                                -5.66     6.32     7.10       9.62
   CR7             Capital Resource Fund (10/81)                    15.52    19.77    14.36      14.83
   CM7             Cash Management Fund (10/81)                     -2.88     3.37     3.86       5.52
   DE7             Diversified Equity Income Fund (9/99)             --       --       --        -3.95
   EM7             Emerging Markets Fund (5/00)+                     --       --       --          --
   EI7             Extra Income Fund (5/96)                         -1.48     --       --         3.23
   FI7             Federal Income Fund (9/99)                        --       --       --        -6.03
   GB7             Global Bond Fund (5/96)                         -11.29     --       --         1.75
   GR7             Growth Fund (9/99)                                --       --       --        10.89
   IE7             International Fund (1/92)                        37.19    14.53     --        12.25
   MF7             Managed Fund (4/86)                               6.70    16.62    12.41      11.76
   ND7             New Dimensions Fund(R)(5/96)                      23.70     --                   --
   IV7             S&P 500 Index Fund (5/00)+                        --       --       --          --
   SC7             Small Cap Advantage Fund (9/99)                   --       --       --         5.35
   SA7             Strategy Aggressive Fund (1/92)                  62.36    23.22     --        15.86
             AIM V.I.
   7CA             Capital Appreciation Fund (5/93)                 36.21    24.01     --        21.01
   7CD             Capital Development Fund (5/98)                  20.82     --       --         6.11
             American Century variable portfolios, inc.
   7IF             VP International (5/94)                          55.44    20.59     --        16.82
   7VA             VP Value (5/96)                                  -8.02     --       --         8.92
             CALVERT CVS
   7SR             Social Balanced Portfolio (9/86)                  4.13    11.73    11.22      14.68
             FIDELITY VIP
   7GI             III Growth & Income Portfolio (Service Class)    -0.14     --       --        18.21
                   (12/96)
   7MP             III Mid Cap Portfolio (Service Class) (12/98)    40.28     --       --        44.40
   7OS             Overseas Portfolio (Service Class) (12/87)       33.99    15.71    10.29      11.29
             FRANKLIN TEMPLETON VIP TRUST
   7RE             Franklin Real Estate Fund - Class 2 (1/89)***   -13.38     5.82     7.59       7.28
   7SI             Franklin Value Securities Fund - Class 2         -5.95     --       --       -17.35
                   (5/98)***
   7IS             Templeton International Smaller Companies        15.70     --       --         2.96
                   Fund - Class 2 (5/96)***
             GOLDMAN SACHS VIT
   7SE             CORESM Small Cap Equity Fund (2/98)****           9.37     --       --        -1.20
   7UE             CORESM U.S. Equity Fund (2/98)                   16.07     --       --        16.30
   7MC             Mid Cap Value Fund (4/98)                        -8.11     --       --       -13.20
             JANUS ASPEN SERIES
   7AG             Aggressive Growth Portfolio - Service Shares    114.13    34.27     --        32.61
                   (9/93)
   7GT             Global Technology Portfolio - Service Shares      --       --       --          --
                   1/00) +
   7IG             International Growth Portfolio - Service         70.84    31.72     --        27.10
                   Shares (4/94)
             LAZARD RETIREMENT SERIES
   7IP             International Equity Portfolio (9/98)            13.21     --       --        20.06
             MFS(R) VARIABLE INSURANCE TRUST (VIT)
   7MG             Growth Series - Service Class (5/99)              --       --       --        44.04
   7MD             New Discovery Series - Service Class (5/98)      85.33     --       --        33.64


<PAGE>


             PUTNAM VARIABLE TRUST
   7IN             Putnam VT International New Opportunities        93.85     --       --        47.03
                   Fund - Class IB Shares (4/98) *****
   7VS             Putnam VT Vista Fund - Class IB Shares (1/97)    44.18     --       --        28.57
                   *****
             ROYCE CAPITAL FUND
   7MI             Micro-Cap Portfolio (12/96)                      19.85     --       --        14.66
             THIRD AVENUE
   7SV             Value Portfolio (9/99)                            --       --       --         1.19
             WANGER
   7IT             International Small Cap (5/95)                  117.28     --       --        37.13
   7SP             U.S. Small Cap (5/95)                            16.66     --       --        24.82
             WARBURG PINCUS TRUST
   7EG             Emerging Growth Portfolio  (9/99)                 --       --       --        27.51
</TABLE>


*Current  applicable  charges  deducted  from  fund  performance  include  a $30
contract  administrative  charge,  a 0.95%  mortality  and expense  risk fee and
applicable surrender charges.


+ Fund had not commenced operations as of Dec. 31, 1999.


**(Commencement date of the Funds)

***Because no Class 2 Shares were issued until Jan. 6, 1999, Class 2 performance
represents  the  historical  results of Class 1 Shares.  Performance  of Class 2
Shares for periods  after its January 6, 1999  inception  will reflect Class 2's
additional  12b-1  fee  expense  which  also  affects  all  future  performance.


****CoreSM  is a service  mark of Goldman,  Sachs & Co.



*****Each of the above Funds' Class IB Shares commenced  operations on April 30,
1998. For periods prior to inception of Class IB Shares, performance information
for Class IB Shares is based upon  performance  of Class IA Shares (not offered)
of the fund, adjusted to reflect the fees paid by Class IB Shares, including the
12b-1 fee of 0.15%.


<PAGE>


Average Annual Total Return For Qualified  Annuities  (Without  Purchase Payment
Credits) Without Surrender For Periods Ending Dec. 31, 1999


<TABLE>
<CAPTION>

                                                                    Performance Since Commencement of the
                                                                                    Fund*
<S>          <C>                                                   <C>     <C>      <C>       <C>

                                                                                                  Since
Subaccount   Investing In:                                         1 Year  5 Years  10 Years  Commencement
----------   -------------                                         ------  -------  --------  ------------
             AXPSM VARIABLE PORTFOLIO -
   BC8             Blue Chip Advantage Fund (9/99)**                  --%      --%      --%      11.04%
   BD8             Bond Fund (10/81)                                 0.89     7.15     7.31       9.84
   CR8             Capital Resource Fund (10/81)                    22.77    20.39    14.59      15.07
   CM8             Cash Management Fund (10/81)                      3.89     4.27     4.07       5.74
   DE8             Diversified Equity Income Fund (9/99)             --       --       --         2.59
   EM8             Emerging Markets Fund (5/00)+                     --       --       --          --
   EI8             Extra Income Fund (5/96)                          5.39     --       --         4.67
   FI8             Federal Income Fund (9/99)                        --       --       --         0.36
   GB8             Global Bond Fund (5/96)                          -5.18     --       --         3.24
   GR8             Growth Fund (9/99)                                --       --       --        17.96
   IE8             International Fund (1/92)                        13.44     9.78     --         9.12
   MF8             Managed Fund (4/86)                              13.93    17.28    12.64      11.99
   ND8             New Dimensions Fund(R)(5/96)                      30.96     --       --        25.35
   IV8             S&P 500 Index Fund (5/00)+                        --       --       --          --
   SC8             Small Cap Advantage Fund (9/99)                   --       --       --        12.42
   SA8             Strategy Aggressive Fund (1/92)                  69.69    23.81     --        16.09
             AIM V.I.
   8CA             Capital Appreciation Fund (5/93)                 43.49    24.59     --        21.35
   8CD             Capital Development Fund (5/98)                  28.08     --       --        10.31
             American Century variable portfolios, inc.
   8IF             VP International (5/94)                          62.76    21.21     --        17.30
   8VA             VP Value (5/96)                                  -1.65     --       --        10.21
             CALVERT CVS
   8SR             Social Balanced Portfolio (9/86)                 10.93    15.53    11.02      14.48
             FIDELITY VIP
   8GI             III Growth & Income Portfolio (Service Class)     6.83     --       --        19.87
                   (12/96)
   8MP             III Mid Cap Portfolio (Service Class) (12/98)    47.58     --       --        51.63
   8OS             Overseas Portfolio (Service Class) (12/87)       41.27    16.39    10.51      11.51
             FRANKLIN TEMPLETON VIP TRUST
   8RE             Franklin Real Estate Fund - Class 2 (1/89)***    -7.12     7.12     8.13       7.79
   8SI             Franklin Value Securities Fund - Class 2          0.58     --       --       -13.90
                   (5/98)***
   8IS             Templeton International Smaller Companies        22.94     --       --         4.40
                   Fund - Class 2 (5/96)***
             GOLDMAN SACHS VIT
   8SE             CORESM Small Cap Equity Fund (2/98)****          16.58     --       --         2.57
   8UE             CORESM U.S. Equity Fund (2/98)                   23.32     --       --        19.77
   8MC             Mid Cap Value Fund (4/98)                        -1.75     --       --        -9.61
             JANUS ASPEN SERIES
   8AG             Aggressive Growth Portfolio - Service Shares    121.54    34.78     --        32.94
                   ( 9/93)
   8GT             Global Technology Portfolio - Service Shares      --       --       --          --
                   (1/00) +
   8IG             International Growth Portfolio - Service         78.18    32.25     --        27.53
                   Shares (4/94)
             LAZARD RETIREMENT SERIES
   8IP             International Equity Portfolio (9/98)            20.45     --       --        25.22
             MFS(R) VARIABLE INSURANCE TRUST (VIT)
   8MG             Growth Series - Service Class (5/99)              --       --       --        50.84
   8MD             New Discovery Series - Service Class (5/98)      92.13     --       --        40.44


<PAGE>


             PUTNAM VARIABLE TRUST
   8IN             Putnam VT International New Opportunities       101.25     --       --        50.54
                   Fund - Class IB Shares (4/98)*****
   8VS             Putnam VT Vista Fund - Class IB Shares           51.50     --       --        30.03
                   (1/97)*****
             ROYCE CAPITAL FUND
   8MI             Micro-Cap Portfolio (12/96)                      27.13     --       --        16.40
             THIRD AVENUE
   8SV             Value Portfolio (9/99)                            --       --       --         8.12
             WANGER
   8IT             International Small Cap (5/95)                  124.71     --       --        37.67
   8SP             U.S. Small Cap (5/95)                            23.90     --       --        25.44
             WARBURG PINCUS TRUST
   8EG             Emerging Growth Portfolio  (9/99)                 --       --       --        34.58
</TABLE>


*Current  applicable  charges  deducted  from  fund  performance  include  a $30
contract administrative charge and a 0.75% mortality and expense risk fee.

+ Fund had not commenced operations as of Dec. 31, 1999.

**(Commencement date of the Funds)

***Because no Class 2 Shares were issued until Jan. 6, 1999, Class 2 performance
represents  the  historical  results of Class 1 shares.  Performance  of Class 2
Shares for periods  after its January 6, 1999  inception  will reflect Class 2's
additional  12b-1  fee  expense  which  also  affects  all  future  performance.


****CoreSM  is a service  mark of Goldman,  Sachs & Co.

***** Each of the above Funds' Class IB Shares commenced operations on April 30,
1998. For periods prior to inception of Class IB Shares, performance information
for Class IB Shares is based upon  performance  of Class IA shares (not offered)
of the fund, adjusted to reflect the fees paid by Class IB Shares, including the
12b-1 fee of 0.15%.


<PAGE>


Average Annual Total Return For Qualified  Annuities  (Without  Purchase Payment
Credits) With a Surrender For Periods Ending Dec. 31, 1999


<TABLE>
<CAPTION>

                                                                    Performance Since Commencement of the
                                                                                    Fund*
<S>          <C>                                                   <C>     <C>      <C>       <C>

                                                                                                  Since
Subaccount   Investing In:                                         1 Year  5 Years  10 Years  Commencement
----------   -------------                                         ------  -------  --------  ------------
             AXPSM VARIABLE PORTFOLIO -
   BC8             Blue Chip Advantage Fund (9/99)**                  --%      --%      --%        4.04%
   BD8             Bond Fund (10/81)                                -5.47     6.54     7.31       9.84
   CR8             Capital Resource Fund (10/81)                    15.77    20.01    14.59      15.07
   CM8             Cash Management Fund (10/81)                     -2.68     3.59     4.07       5.74
   DE8             Diversified Equity Income Fund (9/99)             --       --       --        -3.89
   EM8             Emerging Markets Fund (5/00)+                     --       --       --          --
   EI8             Extra Income Fund (5/96)                         -1.29     --       --         3.44
   FI8             Federal Income Fund (9/99)                        --       --       --        -5.97
   GB8             Global Bond Fund (5/96)                         -11.11     --       --         1.97
   GR8             Growth Fund (9/99)                                --       --       --        10.96
   IE8             International Fund (1/92)                         6.44     9.22     --         9.12
   MF8             Managed Fund (4/86)                               6.93    16.85    12.64      11.99
   ND8             New Dimensions Fund(R)(5/96)                      23.96     --       --        24.60
   IV8             S&P 500 Index Fund (5/00)+                        --       --       --          --
   SC8             Small Cap Advantage Fund (9/99)                   --       --       --         5.42
   SA8             Strategy Aggressive Fund (1/92)                  62.69    23.47     --        16.09
             AIM V.I.
   8CA             Capital Appreciation Fund (5/93)                 36.49    24.26     --        21.25
   8CD             Capital Development Fund (5/98)                  21.08     --       --         6.33
             American Century variable portfolios, inc.
   8IF             VP International (5/94)                          55.76    20.84     --        17.05
   8VA             VP Value (5/96)                                  -7.83     --       --         9.15
             CALVERT CVS
   8SR             Social Balanced Portfolio (9/86)                  3.93    11.53    11.02      14.48
             FIDELITY VIP
   8GI             III Growth & Income Portfolio (Service Class)     0.06     --       --        18.46
                   (12/96)
   8MP             III Mid Cap Portfolio (Service Class) (12/98)    40.58     --       --        44.71
   8OS             Overseas Portfolio (Service Class) (12/87)       34.27    15.95    10.51      11.51
             FRANKLIN TEMPLETON VIP TRUST
   8RE             Franklin Real Estate Fund - Class 2 (1/89)***   -12.92     6.50     8.13       7.79
   8SI             Franklin Value Securities Fund - Class 2         -5.76     --       --       -17.18
                   (5/98)***
   8IS             Templeton International Smaller Companies        15.94     --       --         3.17
                   Fund - Class 2 (5/96)***
             GOLDMAN SACHS VIT
   8SE             CORESM Small Cap Equity Fund (2/98)****           9.58     --       --        -1.01
   8UE             CORESM U.S. Equity Fund (2/98)                   16.32     --       --        16.55
   8MC             Mid Cap Value Fund (4/98)                        -7.93     --       --       -13.03
             JANUS ASPEN SERIES
   8AG             Aggressive Growth Portfolio - Service Shares    114.54    34.54     --        32.87
                   (9/93)
   8GT             Global Technology Portfolio - Service Shares      --       --       --          --
                   (1/00) +
   8IG             International Growth Portfolio - Service         71.18    31.98     --        27.36
                   Shares (4/94)
             LAZARD RETIREMENT SERIES
   8IP             International Equity Portfolio (9/98)            13.45     --       --        20.31
             MFS(R) VARIABLE INSURANCE TRUST (VIT)
   8MG             Growth Series - Service Class (5/99)              --       --       --        43.84
   8MD             New Discovery Series - Service Class (5/98)      85.13     --       --        33.44


<PAGE>


             PUTNAM VARIABLE TRUST
   8IN             Putnam VT International New Opportunities        94.25     --       --        47.33
                   Fund - Class IB Shares (4/98)*****
   8VS             Putnam VT Vista Fund - Class IB Shares           44.50     --       --        28.84
                   (1/97)*****
             ROYCE CAPITAL FUND
   8MI             Micro-Cap Portfolio (12/96)                      20.13     --       --        14.90
             THIRD AVENUE
   8SV             Value Portfolio (9/99)                            --       --       --         1.25
             WANGER
   8IT             International Small Cap (5/95)                  117.71     --       --        37.40
   8SP             U.S. Small Cap (5/95)                            16.90     --       --        25.07
             WARBURG PINCUS TRUST
   8EG             Emerging Growth Portfolio  (9/99)                 --       --       --        27.58
</TABLE>


*Current  applicable  charges  deducted  from  fund  performance  include  a $30
contract  administrative  charge,  a 0.75%  mortality  and expense  risk fee and
applicable surrender charges.

+ Fund had not commenced operations as of Dec. 31, 1999.

**(Commencement date of the Funds)

***Because no Class 2 Shares were issued until Jan. 6, 1999, Class 2 performance
represents  the  historical  results of Class 1 Shares.  Performance  of Class 2
Shares for periods  after its January 6, 1999  inception  will reflect Class 2's
additional  12b-1  fee  expense  which  also  affects  all  future  performance.


****CoreSM  is a service  mark of Goldman,  Sachs & Co.

*****Each of the above Funds' Class IB Shares commenced  operations on April 30,
1998. For periods prior to inception of Class IB Shares, performance information
for Class IB Shares is based upon  performance  of Class IA Shares (not offered)
of the fund, adjusted to reflect the fees paid by Class IB Shares, including the
12b-1 fee of 0.15%.


<PAGE>

Cumulative Total Return

Cumulative  total return  represents  the  cumulative  change in the value of an
investment for a given period (reflecting change in a subaccount's  accumulation
unit value). We compute cumulative total return by using the following formula:

                                     ERV - P
                                        P

where:                P =  a hypothetical initial payment of $1,000
                    ERV =  Ending  Redeemable  Value of a hypothetical  $1,000
                           payment made at the  beginning of the period,  at the
                           end of the period (or fractional portion thereof).

Total return figures reflect the deduction of the surrender charge which assumes
you withdraw the entire  contract value at the end of the one, five and ten year
periods  (or,  if  less,  up to the  life of the  subaccount).  We also may show
performance  figures without the deduction of a surrender  charge.  In addition,
total  return  figures  reflect the  deduction of all other  applicable  charges
including the contract administrative charge and mortality and expense risk fee.

Annualized Calculation of Yield for Subaccounts Investing in Money Market Funds

Annualized Simple Yield

For the  subaccounts  investing in money market  funds,  we base  quotations  of
simple yield on:

(a)  the change in the value of a hypothetical  subaccount (exclusive of capital
     changes and income  other than  investment  income) at the  beginning  of a
     particular seven-day period;

(b)  less a pro rata share of the subaccount expenses accrued over the period;

(c)  dividing this difference by the value of the subaccount at the beginning of
     the period to obtain the base period return;  and

(d)  multiplying the base period return by 365/7.

The  subaccount's value includes:

o any declared dividends,

o the value of any shares purchased with dividends paid during the period, and

o any dividends declared for such shares.

It does not include:

o the effect of any applicable surrender charge, or

o any realized or unrealized gains or losses.

Annualized Compound Yield

We calculate  compound yield using the base period return described above, which
we then compound according to the following formula:

Compound Yield = [(Base Period Return + 1)365/7] -1

<PAGE>

You must consider  (when  comparing an investment  in  subaccounts  investing in
money market funds with fixed  annuities)  that fixed annuities often provide an
agreed-to  or  guaranteed  yield  for a  stated  period  of  time,  whereas  the
subaccount's  yield  fluctuates.  In comparing the yield of the  subaccount to a
money market fund, you should consider the different  services that the contract
provides.

Annualized Yield for Subaccounts Investing in Income Funds

For the  subaccounts  investing in income funds,  we base quotations of yield on
all investment  income earned during a particular  30-day period,  less expenses
accrued during the period (net investment income) and compute it by dividing net
investment  income per accumulation unit by the value of an accumulation unit on
the last day of the period, according to the following formula:

                           YIELD = 2[( a-b + 1)6 - 1]
                                       cd

where:     a =  dividends and investment income earned during the period
           b =  expenses accrued for the period (net of reimbursements)
           c =  the average daily number of accumulation units outstanding
                during the period that were entitled to receive dividends
           d =  the maximum offering price per accumulation unit on the last day
                of the period

The subaccount earns yield from the increase in the net asset value of shares of
the fund in which it invests and from  dividends  declared and paid by the fund,
which are automatically invested in shares of the fund.

The yield on the subaccount's accumulation unit may fluctuate daily and does not
provide a basis for determining future yields.

Independent rating or statistical services or publishers or publications such as
those listed  below may quote  subaccount  performance,  compare it to rankings,
yields or returns,  or use it in variable  annuity  accumulation  or  settlement
illustrations they publish or prepare.

         The Bank Rate Monitor  National  Index,  Barron's,  Business  Week, CDA
         Technologies,  Donoghue's Money Market Fund Report,  Financial Services
         Week,  Financial  Times,  Financial  World,  Forbes,   Fortune,  Global
         Investor,   Institutional  Investor,   Investor's  Daily,   Kiplinger's
         Personal  Finance,  Lipper  Analytical  Services,  Money,  Morningstar,
         Mutual  Fund  Forecaster,   Newsweek,  The  New  York  Times,  Personal
         Investor,  Stanger Report, Sylvia Porter's Personal Finance, USA Today,
         U.S. News and World Report,  The Wall Street  Journal and  Wiesenberger
         Investment Companies Service.

CALCULATING ANNUITY PAYOUTS

The Variable Account

We do the following  calculations  separately for each of the subaccounts of the
variable  account.  The separate monthly payouts,  added together,  make up your
total variable annuity payout.

Initial Payout: To compute your first monthly payment, we:

o    determine the dollar value of your  contract as of the valuation  date that
     falls on (or closest to the  valuation  date that falls before) the seventh
     calendar  day before the  settlement  date and then  deduct any  applicable
     premium tax; then

o    apply the result to the annuity table  contained in the contract or another
     table at least as favorable.

<PAGE>

The annuity table shows the amount of the first monthly  payment for each $1,000
of value which depends on factors built into the table, as described below.

Annuity Units: We then convert the value of your subaccount to annuity units. To
compute the number of units credited to you, we divide the first monthly payment
by the annuity unit value (see below) on the valuation date. The number of units
in your  subaccount  is  fixed.  The  value  of the  units  fluctuates  with the
performance of the underlying fund.

Subsequent Payouts: To compute later payouts, we multiply:

o    the annuity unit value on the  valuation  date that falls on (or closest to
     the valuation  date that falls before) the seventh  calendar day before the
     payout is due; by

o    the fixed number of annuity units credited to you.

Annuity Unit Values: We originally set this value at $1 for each subaccount.  To
calculate later values we multiply the last annuity value by the product of:

o    the net investment factor; and

o    the neutralizing factor.

The  purpose of the  neutralizing  factor is to offset the effect of the assumed
rate built into the annuity table.  With an assumed  investment  rate of 5%, the
neutralizing factor is 0.999866 for a one day valuation period.

Net Investment Factor:

We determine the net investment factor by:

o    adding  the  fund's  current  net asset  value per share plus the per share
     amount of any accrued  income or capital gain dividends to obtain a current
     adjusted net asset value per share; then

o    dividing that sum by the previous adjusted net asset value per share; and

o    subtracting the percentage  factor  representing  the mortality and expense
     risk fee from the result.

Because the net asset value of the fund may fluctuate, the net investment factor
may be greater or less than one,  and the  annuity  unit value may  increase  or
decrease. You bear this investment risk in a variable subaccount.

The Fixed Account

We guarantee your fixed annuity payout  amounts.  Once  calculated,  your payout
will remain the same and never change. To calculate your annuity payouts we:

o    take the value of your fixed account at the settlement date or the date you
     selected to begin receiving your annuity payouts; then

o    using an annuity table,  we apply the value according to the annuity payout
     plan you select.

The annuity payout table we use will be the one in effect at the time you choose
to begin  your  annuity  payouts.  The  values in the table  will be equal to or
greater than the table in your contract.

<PAGE>

RATING AGENCIES

The  following  chart  reflects the ratings  given to us by  independent  rating
agencies.  These  agencies  evaluate the financial  soundness and  claims-paying
ability of  insurance  companies  based on a number of different  factors.  This
information  does not relate to the management or performance of the subaccounts
of the contract. This information relates only to the fixed account and reflects
our  ability  to make  annuity  payouts  and to pay  death  benefits  and  other
distributions from the contract.


    Rating Agency              Rating

      A.M. Best                  A+
                             (Superior)

    Duff & Phelps               AAA

       Moody's                  Aa2

PRINCIPAL UNDERWRITER

The  principal  underwriter  for the  contract  is  American  Express  Financial
Advisors, Inc. (AEFA) which offers the contract on a continuous basis.

The contract is new and,  therefore,  we have not received any surrender charges
or paid any commissions.

INDEPENDENT AUDITORS

The  financial  statements  appearing  in this SAI have been  audited by Ernst &
Young LLP (1400 Pillsbury Center, 200 South Sixth Street, Minneapolis, MN 55402)
independent auditors, as stated in their report appearing herein.

FINANCIAL STATEMENTS

<PAGE>


<PAGE>
IDS LIFE INSURANCE COMPANY OF NEW YORK
FINANCIAL INFORMATION

REPORT OF INDEPENDENT AUDITORS

THE BOARD OF DIRECTORS
IDS LIFE INSURANCE COMPANY OF NEW YORK
We have audited the accompanying balance sheets of IDS Life Insurance Company of
New York (a wholly-owned subsidiary of IDS Life Insurance Company) as of
December 31, 1999 and 1998, and the related statements of income, stockholder's
equity and cash flows for each of the three years in the period ended December
31, 1999. These financial statements are the responsibility of the Company's
management. Our responsibility is to express an opinion on these financial
statements based on our audits.

We conducted our audits in accordance with auditing standards generally accepted
in the United States. Those standards require that we plan and perform the audit
to obtain reasonable assurance about whether the financial statements are free
of material misstatement. An audit includes examining, on a test basis, evidence
supporting the amounts and disclosures in the financial statements. An audit
also includes assessing the accounting principles used and significant estimates
made by management, as well as evaluating the overall financial statement
presentation. We believe that our audits provide a reasonable basis for our
opinion.

In our opinion, the financial statements referred to above present fairly, in
all material respects, the financial position of IDS Life Insurance Company of
New York at December 31, 1999 and 1998, and the results of its operations and
its cash flows for each of the three years in the period ended December 31,
1999, in conformity with accounting principles generally accepted in the
United States.

ERNST & YOUNG LLP
February 3, 2000
Minneapolis, Minnesota

--------------------------------------------------------------------------------

                                      IDS LIFE INSURANCE COMPANY OF NEW YORK F-1
<PAGE>
IDS LIFE INSURANCE COMPANY OF NEW YORK

BALANCE SHEETS

<TABLE>
<CAPTION>
DECEMBER 31, ($ THOUSANDS)                   1999         1998
<S>                                       <C>          <C>
 ASSETS
-----------------------------------------------------------------
Investments:
  Fixed maturities:
    Held to maturity, at amortized cost
    (fair value:
    1999, $432,004; 1998, $503,909)       $  434,343   $  473,592
    Available for sale, at fair value
    (amortized cost:
    1999, $579,014; 1998, $561,325)          555,574      578,591
-----------------------------------------------------------------
                                             989,917    1,052,183
Mortgage loans on real estate                154,062      166,835
Policy loans                                  27,528       25,421
Other investments                                 --          566
-----------------------------------------------------------------
    Total investments                      1,171,507    1,245,005
Cash and cash equivalents                      8,131        3,007
Amounts recoverable from reinsurers            6,914        4,077
Accounts receivable                              567          842
Premiums due                                     199          204
Accrued investment income                     18,365       19,893
Deferred policy acquisition costs            136,229      129,477
Deferred income taxes                          3,881           --
Other assets                                     723        1,042
Separate account assets                    1,957,703    1,491,679
-----------------------------------------------------------------
Total assets                              $3,304,219   $2,895,226
-----------------------------------------------------------------

 LIABILITIES AND STOCKHOLDER'S EQUITY
-----------------------------------------------------------------
Liabilities:
Future policy benefits:
Fixed annuities                           $  821,992   $  875,507
Universal life-type insurance                156,420      152,195
Traditional life, disability income and
  long-term care insurance                    64,278       55,910
Policy claims and other policyholders'
  funds                                        2,584        3,105
Deferred income taxes                             --        7,912
Amounts due to brokers                            --        4,507
Other liabilities                             21,432       24,945
Separate account liabilities               1,957,703    1,491,679
-----------------------------------------------------------------
Total liabilities                          3,024,409    2,615,760
-----------------------------------------------------------------
Stockholder's equity:
  Capital stock, $10 par value per
  share;
200,000 shares authorized, issued and
  outstanding                                  2,000        2,000
Additional paid-in capital                    49,000       49,000
Accumulated other comprehensive (loss)
  income:
Net unrealized securities (losses) gains     (14,966)      11,014
-----------------------------------------------------------------
Retained earnings                            243,776      217,452
-----------------------------------------------------------------
Total stockholder's equity                   279,810      279,466
-----------------------------------------------------------------
Total liabilities and stockholder's
  equity                                  $3,304,219   $2,895,226
=================================================================
</TABLE>

See accompanying notes.

--------------------------------------------------------------------------------

F-2      IDS LIFE INSURANCE COMPANY OF NEW YORK
<PAGE>
IDS LIFE INSURANCE COMPANY OF NEW YORK

STATEMENTS OF INCOME

<TABLE>
<CAPTION>
YEARS ENDED DECEMBER 31, ($ THOUSANDS)                          1999       1998       1997
<S>                                                           <C>        <C>        <C>
 REVENUES:
--------------------------------------------------------------------------------------------
Traditional life, disability income and long-term care
  insurance premiums                                          $ 15,613   $ 13,852   $ 12,376
Policyholder and contractholder charges                         22,502     20,467     18,319
Mortality and expense risk fees                                 17,019     13,980     11,312
Net investment income                                           95,514    100,871    106,274
Net realized gains on investments                                1,386      2,163        547
--------------------------------------------------------------------------------------------
Total revenues                                                 152,034    151,333    148,828
--------------------------------------------------------------------------------------------

 BENEFITS AND EXPENSE:
--------------------------------------------------------------------------------------------
Death and other benefits:
Traditional life, disability income and long-term care
  insurance                                                      5,579      5,553      3,633
Universal life-type insurance and investment contracts           6,313      4,320      3,852
Increase in liabilities for future policy benefits for for
  traditional life, disability income and long-term care
  insurance                                                      6,098      3,662      3,979
Interest credited on universal life-type insurance and
  investment contracts                                          50,767     55,073     62,294
Amortization of deferred policy acquisition costs               15,787     18,362     17,201
Other insurance and operating expenses                           9,925      8,917     10,220
--------------------------------------------------------------------------------------------
Total benefits and expenses                                     94,469     95,887    101,179
--------------------------------------------------------------------------------------------
Income before income taxes                                      57,565     55,446     47,649
Income taxes                                                    19,241     19,098     16,471
--------------------------------------------------------------------------------------------
Net income                                                    $ 38,324   $ 36,348   $ 31,178
============================================================================================
</TABLE>

See accompanying notes.

--------------------------------------------------------------------------------

                                      IDS LIFE INSURANCE COMPANY OF NEW YORK F-3
<PAGE>
IDS LIFE INSURANCE COMPANY OF NEW YORK

STATEMENTS OF STOCKHOLDER'S EQUITY

<TABLE>
<CAPTION>
                                                                                            ACCUMULATED
                                                                                               OTHER
                                                        TOTAL                  ADDITIONAL  COMPREHENSIVE
                                                    STOCKHOLDER'S   CAPITAL     PAID-IN    (LOSS) INCOME,   RETAINED
THREE YEARS ENDED DECEMBER 31, 1999 ($ THOUSANDS)      EQUITY        STOCK      CAPITAL      NET OF TAX     EARNINGS
<S>                                                 <C>            <C>         <C>         <C>             <C>
 COMPREHENSIVE INCOME:
---------------------------------------------------------------------------------------------------------------------
Balance, December 31, 1996                            $ 229,863     $ 2,000     $ 49,000       $  6,937     $171,926
Net income                                               31,178          --           --             --       31,178
Unrealized holding gains arising during the year,
  net of deferred policy acquisition costs of ($1)
  and taxes of ($3,412)                                   6,337          --           --          6,337           --
Reclassification adjustment for gains included in
  net income, net of tax of $54                             (99)         --           --            (99)          --
Other comprehensive income                                6,238          --           --          6,238           --
---------------------------------------------------------------------------------------------------------------------
Comprehensive income                                     37,416                                      --           --
Cash dividends to parent                                (10,000)         --           --             --      (10,000)
---------------------------------------------------------------------------------------------------------------------

 COMPREHENSIVE INCOME:
---------------------------------------------------------------------------------------------------------------------
Balance, December 31, 1997                              257,279       2,000       49,000         13,175      193,104
Net income                                               36,348          --           --             --       36,348
Unrealized holding losses arising during the year,
  net of deferred policy acquisition costs of $22
  and taxes of $1,415                                    (2,628)         --           --         (2,628)          --
Reclassification adjustment for losses included in
  net income, net of tax of ($252)                          467          --           --            467           --
---------------------------------------------------------------------------------------------------------------------
Other comprehensive loss                                 (2,161)         --           --         (2,161)          --
Comprehensive income                                     34,187                                      --           --
---------------------------------------------------------------------------------------------------------------------
Cash dividends to parent                                (12,000)         --           --             --      (12,000)
---------------------------------------------------------------------------------------------------------------------
Balance, December 31, 1998                              279,466       2,000       49,000         11,014      217,452

 COMPREHENSIVE INCOME:
---------------------------------------------------------------------------------------------------------------------
Balance, December 31, 1998                              279,466       2,000       49,000         11,014      217,452
Net income                                               38,324          --           --             --       38,324
Unrealized holding losses arising during the year,
  net of deferred policy acquisition costs of $737
  and of taxes of $13,537                               (25,140)         --           --        (25,140)          --
Reclassification adjustment for gains included in
  net income, net of tax of $452                           (840)         --           --           (840)          --
---------------------------------------------------------------------------------------------------------------------
Other comprehensive loss                                (25,980)         --           --        (25,980)          --
Comprehensive income                                     12,344                                      --           --
---------------------------------------------------------------------------------------------------------------------
Cash dividends to parent                                (12,000)         --           --             --      (12,000)
---------------------------------------------------------------------------------------------------------------------
Balance, December 31, 1999                            $ 279,810     $ 2,000     $ 49,000       $(14,966)    $243,776
---------------------------------------------------------------------------------------------------------------------
</TABLE>

See accompanying notes.

--------------------------------------------------------------------------------

F-4      IDS LIFE INSURANCE COMPANY OF NEW YORK
<PAGE>
IDS LIFE INSURANCE COMPANY OF NEW YORK

STATEMENTS OF CASH FLOWS

<TABLE>
<CAPTION>
YEARS ENDED DECEMBER 31, ($ THOUSANDS)                          1999        1998        1997
<S>                                                           <C>         <C>         <C>
 CASH FLOWS FROM OPERATING ACTIVITIES:
-----------------------------------------------------------------------------------------------
Net income                                                    $  38,324   $  36,348   $  31,178
Adjustments to reconcile net income to net cash provided by
  operating activities:
Policy loans, excluding universal life-type insurance:
Issuance                                                         (3,063)     (3,110)     (3,073)
Repayment                                                         2,826       2,660       1,897
Change in accrued investment income                               1,528         312         863
Change in amounts recoverable from reinsurer                     (2,837)     (1,760)     (1,345)
Change in premiums due                                                5         (12)        (50)
Change in accounts receivable                                       275        (119)        218
Change in other assets                                              319         (47)        (95)
Change in deferred policy acquisition costs, net                 (6,015)     (2,841)     (7,431)
Change in liabilities for future policy benefits for
  traditional life, disability income and long-term care
  insurance                                                       8,368       5,441       5,131
Change in policy claims and other policyholders' funds             (522)       (908)        858
Deferred income tax provision (benefit)                           2,196      (2,369)       (960)
Change in other liabilities                                      (3,513)     (3,986)      3,468
Accretion of discount, net                                       (1,794)       (342)       (352)
Net realized gain on investments                                 (1,386)     (2,163)       (547)
Policyholder and contractholder charges, non-cash                (9,875)     (9,661)     (8,772)
Other, net                                                        1,859         118         715
-----------------------------------------------------------------------------------------------
Net cash provided by operating activities                     $  26,695   $  17,561   $  21,703

 CASH FLOWS FROM INVESTING ACTIVITIES:
-----------------------------------------------------------------------------------------------
Fixed maturities held to maturity:
Maturities, sinking fund payments and calls                   $  37,852   $  46,629   $  36,511
Sales                                                               790      16,173      12,616
Fixed maturities available for sale:
Purchases                                                      (155,690)    (86,072)   (101,818)
Maturities, sinking fund payments and calls                      50,515      96,578      84,229
Sales                                                            89,683      13,180      27,055
Other investments, excluding policy loans:
Purchases                                                        (3,598)     (9,121)    (33,243)
Sales                                                            16,671      21,113      14,233
Change in amounts due from brokers                                   --          --         995
Change in amounts due to brokers                                 (4,507)    (24,547)     26,047
-----------------------------------------------------------------------------------------------
Net cash provided by investing activities                        31,716      73,933      66,625

 CASH FLOWS FROM FINANCING ACTIVITIES:
-----------------------------------------------------------------------------------------------
Activity related to universal life-type insurance and
  investment contracts:
Considerations received                                          68,978      76,009     112,732
Surrenders and death benefits                                  (159,161)   (205,946)   (251,259)
Interest credited to account balances                            50,767      55,073      62,294
Universal life-type insurance policy loans:
Issuance                                                         (5,057)     (5,222)     (4,848)
Repayment                                                         3,186       3,599       2,753
Cash dividend to parent                                         (12,000)    (12,000)    (10,000)
-----------------------------------------------------------------------------------------------
Net cash used in financing activities                           (53,287)    (88,487)    (88,328)
-----------------------------------------------------------------------------------------------
Net increase in cash and cash equivalents                         5,124       3,007          --
Cash and cash equivalents at beginning of year                    3,007          --          --
-----------------------------------------------------------------------------------------------
Cash and cash equivalents at end of year                      $   8,131   $   3,007   $      --
-----------------------------------------------------------------------------------------------
</TABLE>

See accompanying notes.

--------------------------------------------------------------------------------

                                      IDS LIFE INSURANCE COMPANY OF NEW YORK F-5
<PAGE>
NOTES TO FINANCIAL STATEMENTS ($ THOUSANDS)

1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

NATURE OF BUSINESS
IDS Life Insurance Company of New York (the Company) is engaged in the insurance
and annuity business in the state of New York. The Company's principal products
are deferred annuities and universal life insurance which are issued primarily
to individuals. It offers single premium and flexible premium deferred annuities
on both a fixed and variable dollar basis. Immediate annuities are offered as
well. The Company's insurance products include universal life (fixed and
variable), whole life, single premium life and term products (including waiver
of premium and accidental death benefits). The Company also markets disability
income and long-term care insurance.

BASIS OF PRESENTATION
The Company is a wholly owned subsidiary of IDS Life Insurance Company (IDS
Life), which is a wholly owned subsidiary of American Express Financial
Corporation (AEFC), which is a wholly owned subsidiary of American Express
Company. The accompanying financial statements have been prepared in conformity
with accounting principles generally accepted in the United States which vary in
certain respects from reporting practices prescribed or permitted by the New
York Department of Insurance as reconciled in Note 11.

The preparation of financial statements in conformity with accounting principles
generally accepted in the United States requires management to make estimates
and assumptions that affect the reported amounts of assets and liabilities and
disclosure of contingent assets and liabilities at the date of the financial
statements and the reported amounts of revenues and expenses during the
reporting period. Actual results could differ from those estimates.

INVESTMENTS
Fixed maturities that the Company has both the positive intent and the ability
to hold to maturity are classified as held to maturity and carried at amortized
cost. All other fixed maturities and all marketable equity securities are
classified as available for sale and carried at fair value. Unrealized gains and
losses on securities classified as available for sale are reported as a separate
component of accumulated other comprehensive (loss) income, net of deferred
policy acquisition costs and deferred income taxes.

Realized investment gains or losses are determined on an identified cost basis.

Prepayments are anticipated on certain investments in mortgage-backed securities
in determining the constant effective yield used to recognize interest income.
Prepayment estimates are based on information received from brokers who deal in
mortgage-backed securities.

Mortgage loans on real estate are carried at amortized cost less reserves for
mortgage loan losses. The estimated fair value of the mortgage loans is
determined by a discounted cash flow analysis using mortgage interest rates
currently offered for mortgages of similar maturities.

Impairment of mortgage loans is measured as the excess of the loan's recorded
investment over its present value of expected principal and interest payments
discounted at the loan's effective interest rate, or the fair value of
collateral. The amount of the impairment is recorded in an allowance for
mortgage loan losses. The allowance for mortgage loan losses is maintained at a
level that management believes is adequate to absorb estimated losses in the
portfolio. The level of the allowance account is determined based on several
factors, including historical experience, expected future principal and interest
payments, estimated collateral

--------------------------------------------------------------------------------

F-6      IDS LIFE INSURANCE COMPANY OF NEW YORK
<PAGE>
values, and current economic and political conditions. Management regularly
evaluates the adequacy of the allowance for mortgage loan losses.

The Company generally stops accruing interest on mortgage loans for which
interest payments are delinquent more than three months. Based on management's
judgment as to the ultimate collectibility of principal, interest payments
received are either recognized as income or applied to the recorded investment
in the loan.

The cost of interest rate caps is amortized to investment income over the life
of the contracts and payments received as a result of these agreements are
recorded as investment income when realized.

Policy loans are carried at the aggregate of the unpaid loan balances which do
not exceed the cash surrender values of the related policies.

When evidence indicates a decline, which is other than temporary, in the
underlying value or earning power of individual investments, such investments
are written down to the fair value by a charge to income.

STATEMENTS OF CASH FLOWS
The Company considers investments with a maturity at the date of their
acquisition of three months or less to be cash equivalents. These securities are
carried principally at amortized cost which approximates fair value.

Supplementary information to the statements of cash flows for the years ended
December 31 is summarized as follows:

<TABLE>
<CAPTION>
                                      1999     1998     1997
--------------------------------------------------------------
<S>                                  <C>      <C>      <C>
Cash paid during the year for:
Income taxes                         $20,670  $22,470  $17,811
Interest on borrowings                   124    1,600    1,026
</TABLE>

RECOGNITION OF PROFITS ON ANNUITY CONTRACTS AND INSURANCE POLICIES
Profits on fixed deferred annuities are recognized by the Company over the lives
of the contracts, using primarily the interest method. Profits represent the
excess of investment income earned from investment of contract considerations
over interest credited to contract owners and other expenses.

The retrospective deposit method is used in accounting for universal life-type
insurance. This method recognizes profits over the lives of the policies in
proportion to the estimated gross profits expected to be realized.

Premiums on traditional life, disability income and long-term care insurance
policies are recognized as revenue when due, and related benefits and expenses
are associated with premium revenue in a manner that results in recognition of
profits over the lives of the insurance policies. This association is
accomplished by means of the provision for future policy benefits and the
deferral and subsequent amortization of policy acquisition costs.

Policyholder and contractholder charges include the monthly cost of insurance
charges, issue and administrative fees and surrender charges. These charges also
include the minimum death benefit guarantee fees received from the variable life
insurance separate accounts. Mortality and expense fees are received from the
variable annuity and variable life insurance separate accounts.

DEFERRED POLICY ACQUISITION COSTS
The costs of acquiring new business, principally sales compensation, policy
issue costs, underwriting and certain sales expenses, have been deferred on
insurance and annuity contracts. The deferred acquisition costs for most single
premium deferred annuities

--------------------------------------------------------------------------------

                                      IDS LIFE INSURANCE COMPANY OF NEW YORK F-7
<PAGE>
and installment annuities are amortized primarily using the interest method. The
costs for universal life-type insurance and certain installment annuities are
amortized as a percentage of the estimated gross profits expected to be realized
on the policies. For traditional life, disability income and long-term care
insurance policies, the costs are amortized over an appropriate period in
proportion to premium revenue.

Amortization of deferred policy acquisition costs requires the use of
assumptions including interest margins, mortality margins, persistency rates,
maintenance expense levels and, for variable products, separate account
performance. For universal life-type insurance and deferred annuities, actual
experience is reflected in the Company's amortization models monthly. As actual
experience differs from the current assumptions, management considers the need
to change key assumptions underlying the amortization models prospectively. The
impact of changing prospective assumptions is reflected in the period that such
changes are made and is generally referred to as an unlocking adjustment. Net
unlocking adjustments in 1999, 1998 and 1997 were not significant.

LIABILITIES FOR FUTURE POLICY BENEFITS
Liabilities for universal-life type insurance and fixed and variable deferred
annuities are accumulation values.

Liabilities for equity indexed deferred annuities are determined as the present
value of guaranteed benefits and the intrinsic value of index-based benefits.

Liabilities for future benefits on traditional life insurance are based on the
net level premium method, using anticipated mortality, policy persistency and
interest earning rates. Anticipated mortality rates are based on established
industry mortality tables. Anticipated policy persistency rates vary by policy
form, issue age and policy duration with persistency on cash value plans
generally anticipated to be better than persistency on term insurance plans.
Anticipated interest rates range from 4% to 10%, depending on policy form, issue
year and policy duration.

Liabilities for future disability income and long-term care policy benefits
include both policy reserves and claim reserves. Policy reserves are based on
the net level premium method, using anticipated morbidity, mortality, policy
persistency and interest earning rates. Anticipated morbidity and mortality
rates are based on established industry morbidity and mortality tables.
Anticipated policy persistency rates vary by policy form, issue age, policy
duration and, for disability income policies, occupation class. Anticipated
interest rates for disability income and long-term care policy reserves are 3%
to 9.5% at policy issue and grade to ultimate rates of 5% to 7% over 4 to 10
years.

Claim reserves are calculated based on claim continuance tables and anticipated
interest earnings. Anticipated claim continuance rates are based on established
industry tables. Anticipated interest rates for claim reserves for both
disability income and long-term care range from 5% to 8%.

REINSURANCE
The maximum amount of life insurance risk retained by the Company is $750 on any
policy insuring a single life and $1,500 on any policy insuring a joint-life
combination. Risk not retained is reinsured with other life insurance companies,
primarily on a yearly renewable term basis. Long-term care policies are
primarily reinsured on a coinsurance basis. The Company retains all disability
income and waiver of premium risk. Beginning in 2000, the Company will retain
all accidental death benefit risk.

FEDERAL INCOME TAXES
The Company's taxable income is included in the consolidated federal income tax
return of American Express Company. The Company provides for income taxes on a
separate return basis, except that, under an agreement between AEFC and American

--------------------------------------------------------------------------------

F-8      IDS LIFE INSURANCE COMPANY OF NEW YORK
<PAGE>
Express Company, tax benefit is recognized for losses to the extent they can be
used on the consolidated tax return. It is the policy of AEFC and its
subsidiaries that AEFC will reimburse subsidiaries for all tax benefits.

Included in other liabilities at December 31, 1999 and 1998 are $366, and
$3,647, respectively, payable to IDS Life for federal income taxes.

SEPARATE ACCOUNT BUSINESS
The separate account assets and liabilities represent funds held for the
exclusive benefit of the variable annuity and variable life insurance contract
owners. The Company receives mortality and expense risk fees from the variable
annuity separate accounts.

The Company makes contractual mortality assurances to the variable annuity
contract owners that the net assets of the separate accounts will not be
affected by future variations in the actual life expectancy experience of the
annuitants and beneficiaries from the mortality assumptions implicit in the
annuity contracts. The Company makes periodic fund transfers to, or withdrawals
from, the separate account assets for such actuarial adjustments for variable
annuities that are in the benefit payment period. The Company also guarantees
that the rates at which administrative fees are deducted from contract funds
will not exceed contractual maximums.

For variable life insurance, the Company guarantees that the rates at which
insurance charges and administrative fees are deducted from contract funds will
not exceed contractual maximums. The Company also guarantees that the death
benefit will continue payable at the initial level regardless of investment
performance so long as minimum premium payments are made.

ACCOUNTING CHANGES
American Institute of Certified Public Accountants (AICPA) Statement of Position
(SOP) 98-1, "Accounting for Costs of Computer Software Developed or Obtained for
Internal Use" became effective January 1, 1999. The SOP requires the
capitalization of certain costs incurred after the date of adoption to develop
or obtain software for internal use. Software utilized by the Company is owned
by AEFC and capitalized by AEFC. As a result, the new rule did not have a
material impact on the Company's results of operations or financial condition.

Effective January 1, 1999, the Company adopted AICPA SOP 97-3, "Accounting by
Insurance and Other Enterprises for Insurance-Related Assessments," providing
guidance for the timing of recognition of liabilities related to guaranty fund
assessments. The Company had historically carried a balance in other liabilities
on the balance sheet for potential guaranty fund assessment exposure. Adoption
of the SOP did not have a material impact on the Company's results of operations
or financial condition.

In June 1998, the Financial Accounting Standards Board issued Statement of
Financial Accounting Standards No. 133, "Accounting for Derivative Instruments
and Hedging Activities," which is effective January 1, 2001. This Statement
establishes accounting and reporting standards for derivative instruments,
including certain derivative instruments embedded in other contracts, and for
hedging activities. It requires that an entity recognize all derivatives as
either assets or liabilities in the balance sheet and measure those instruments
at fair value. The accounting for changes in the fair value of a derivative
depends on the intended use of the derivative and the resulting designation. The
ultimate financial effect of the new rule will be measured based on the
derivatives in place at adoption and cannot be estimated at this time.

PERMITTED STATUTORY ACCOUNTING PRACTICES
The Company's statutory-basis financial statements are prepared in accordance
with accounting practices prescribed or permitted by the New York Insurance
Department. Currently, "prescribed" statutory practices are interspersed
throughout state insurance laws and regulations, the NAIC ACCOUNTING PRACTICES
AND PROCEDURES MANUAL and a variety of other NAIC publications. "Permitted"

--------------------------------------------------------------------------------

                                      IDS LIFE INSURANCE COMPANY OF NEW YORK F-9
<PAGE>
statutory accounting practices encompass all accounting practices that are not
prescribed: such practices may differ from state to state, may differ from
company to company within a state, and may change in the future.

In 1998, the NAIC adopted codified statutory accounting principles
("Codification") effective January 1, 2001. Codification will likely change, to
some extent, prescribed statutory accounting practices and may result in changes
to the accounting practices that the Company uses to prepare its statutory-basis
financial statements. Codification will require adoption by the various states
before it becomes the prescribed statutory basis of accounting for insurance
companies domesticated within those states. Accordingly, before Codification
becomes effective for the Company, the State of New York must adopt Codification
as the prescribed basis of accounting on which domestic insurers must report
their statutory-basis results to the Insurance Department. New York has not yet
made a decision regarding whether or not it will accept Codification. While
management has not yet determined the impact of Codification to the Company's
statutory-basis financial statements, it does not believe the impact will be
material.

RECLASSIFICATIONS
Certain 1998 and 1997 amounts have been reclassified to conform to the 1999
presentation.

2. INVESTMENTS

Fair values of investments in fixed maturities represent quoted market prices
and estimated values when quoted prices are not available. Estimated values are
determined by established procedures involving, among other things, review of
market indices, price levels of current offerings of comparable issues, price
estimates and market data from independent brokers and financial files.

The amortized cost, gross unrealized gains and losses and fair value of
investments in fixed maturities at December 31, 1999 are as follows:

<TABLE>
<CAPTION>
                                                     GROSS       GROSS
                                    AMORTIZED      UNREALIZED  UNREALIZED      FAIR
HELD TO MATURITY                      COST           GAINS       LOSSES        VALUE
----------------------------------------------------------------------------------------
<S>                             <C>                <C>         <C>         <C>
U.S. Government agency
  obligations                       $  2,490        $    20     $   150      $  2,360
Corporate bonds and
  obligations                        384,241          6,066       7,058       383,249
Mortgage-backed securities            47,612            103       1,320        46,395
----------------------------------------------------------------------------------------
                                    $434,343        $ 6,189     $ 8,528      $432,004
----------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------
</TABLE>

<TABLE>
<CAPTION>
                                             GROSS       GROSS
                                AMORTIZED  UNREALIZED  UNREALIZED    FAIR
AVAILABLE FOR SALE                COST       GAINS       LOSSES      VALUE
----------------------------------------------------------------------------
<S>                             <C>        <C>         <C>         <C>
State and municipal
  obligations                   $    104    $     6     $    --    $    110
Corporate bonds and
  obligations                    374,846      2,324      20,325     356,845
Mortgage-backed securities       204,064        580       6,025     198,619
----------------------------------------------------------------------------
                                $579,014    $ 2,910     $26,350    $555,574
----------------------------------------------------------------------------
----------------------------------------------------------------------------
</TABLE>

--------------------------------------------------------------------------------

F-10      IDS LIFE INSURANCE COMPANY OF NEW YORK
<PAGE>
The amortized cost, gross unrealized gains and losses and fair value of
investments in fixed maturities at December 31, 1998 are as follows:

<TABLE>
<CAPTION>
                                             GROSS       GROSS
                                AMORTIZED  UNREALIZED  UNREALIZED    FAIR
HELD TO MATURITY                  COST       GAINS       LOSSES      VALUE
----------------------------------------------------------------------------
<S>                             <C>        <C>         <C>         <C>
U.S. Government agency
  obligations                   $  2,871    $   159     $    --    $  3,030
Corporate bonds and
  obligations                    417,648     29,795         474     446,969
Mortgage-backed securities        53,073        844           7      53,910
----------------------------------------------------------------------------
                                $473,592    $30,798     $   481    $503,909
----------------------------------------------------------------------------
----------------------------------------------------------------------------
</TABLE>

<TABLE>
<CAPTION>
                                             GROSS       GROSS
                                AMORTIZED  UNREALIZED  UNREALIZED    FAIR
AVAILABLE FOR SALE                COST       GAINS       LOSSES      VALUE
----------------------------------------------------------------------------
<S>                             <C>        <C>         <C>         <C>
State and municipal
  obligations                   $    105    $     9     $    --    $    114
Corporate bonds and
  obligations                    336,985     15,939       6,296     346,628
Mortgage-backed securities       224,235      7,614          --     231,849
----------------------------------------------------------------------------
                                $561,325    $23,562     $ 6,296    $578,591
----------------------------------------------------------------------------
----------------------------------------------------------------------------
</TABLE>

The amortized cost and fair value of investments in fixed maturities at December
31, 1999 by contractual maturity are shown below. Expected maturities will
differ from contractual maturities because borrowers may have the right to call
or prepay obligations with or without call or prepayment penalties.

<TABLE>
<CAPTION>
                                                 AMORTIZED    FAIR
HELD TO MATURITY                                   COST      VALUE
--------------------------------------------------------------------
<S>                             <C>      <C>     <C>        <C>
Due in one year or less                          $ 14,966   $ 15,118
Due from one to five years                        213,933    214,972
Due from five to ten years                        111,707    111,314
Due in more than ten years                         46,125     44,205
Mortgage-backed securities                         47,612     46,395
--------------------------------------------------------------------
                                                 $434,343   $432,004
--------------------------------------------------------------------
--------------------------------------------------------------------
</TABLE>

<TABLE>
<CAPTION>
                                                 AMORTIZED    FAIR
AVAILABLE FOR SALE                                 COST      VALUE
--------------------------------------------------------------------
<S>                             <C>      <C>     <C>        <C>
Due in one year or less                          $ 14,422   $ 14,657
Due from one to five years                         37,204     37,477
Due from five to ten years                        214,169    203,150
Due in more than ten years                        109,155    101,671
Mortgage-backed securities                        204,064    198,619
--------------------------------------------------------------------
                                                 $579,014   $555,574
--------------------------------------------------------------------
--------------------------------------------------------------------
</TABLE>

During the years ended December 31, 1999, 1998 and 1997, fixed maturities
classified as held to maturity were sold with amortized cost of $790, $16,175
and $12,737, respectively. Net gains and losses on these sales were not
significant. The sale of these fixed maturities was due to significant
deterioration in the issuers' creditworthiness.

Fixed maturities available for sale were sold during 1999 with proceeds of
$89,683 and gross realized gains and losses of $1,917 and $625, respectively.
Fixed maturities available for sale were sold during 1998 with proceeds of
$13,180 and gross realized gains and

--------------------------------------------------------------------------------

                                     IDS LIFE INSURANCE COMPANY OF NEW YORK F-11
<PAGE>
losses of $1,159 and $440, respectively. Fixed maturities available for sale
were sold during 1997 with proceeds of $27,055 and gross realized gains and
losses of $461 and $309, respectively.

At December 31, 1999, bonds carried at $254 were on deposit with the state of
New York as required by law.

At December 31, 1999, investments in fixed maturities comprised 85 percent of
the Company's total invested assets. These securities are rated by Moody's and
Standard & Poor's (S&P), except for securities carried at approximately $147
million which are rated by AEFC internal analysts using criteria similar to
Moody's and S&P. A summary of investments in fixed maturities, at amortized
cost, by rating on December 31 is as follows:

<TABLE>
<CAPTION>
RATING                                       1999        1998
----------------------------------------------------------------
<S>                                       <C>         <C>
Aaa/AAA                                   $  250,577  $  280,669
Aa/AA                                         12,992      15,815
Aa/A                                          25,489      16,327
A/A                                          150,187     151,838
A/BBB                                         68,417      68,640
Baa/BBB                                      354,331     366,776
Baa/BB                                        23,562      39,666
Below investment grade                       127,802      95,186
----------------------------------------------------------------
                                          $1,013,357  $1,034,917
----------------------------------------------------------------
----------------------------------------------------------------
</TABLE>

At December 31, 1999, 94 percent of the securities rated Aaa/AAA are GNMA, FNMA
and FHLMC mortgage-backed securities. No holdings of any other issuer are
greater than one percent of the Company's total investments in fixed maturities.

At December 31, 1999, approximately 13 percent of the Company's investments were
mortgage loans on real estate. Summaries of mortgage loans by region of the
United States and by type of real estate are as follows:

<TABLE>
<CAPTION>
                                   DECEMBER 31, 1999        DECEMBER 31, 1998
                                ON BALANCE  COMMITMENTS  ON BALANCE  COMMITMENTS
REGION                            SHEET     TO PURCHASE    SHEET     TO PURCHASE
--------------------------------------------------------------------------------
<S>                             <C>         <C>          <C>         <C>
West North Central               $ 22,686      $ --       $ 24,725      $ --
East North Central                 25,195        --         29,134        59
South Atlantic                     31,748        --         34,175       598
Middle Atlantic                    17,672        --         18,350        --
Pacific                             6,751        --          9,706        --
Mountain                           35,608        --         36,636        --
New England                         8,209        --          7,851        --
East South Central                  7,394        --          7,521        --
West South Central                      0        --            237        --
--------------------------------------------------------------------------------
                                  155,262        --        168,335       657
Less allowance for losses           1,200        --          1,500        --
--------------------------------------------------------------------------------
                                 $154,062      $ --       $166,835      $657
--------------------------------------------------------------------------------
--------------------------------------------------------------------------------
</TABLE>

--------------------------------------------------------------------------------

F-12      IDS LIFE INSURANCE COMPANY OF NEW YORK
<PAGE>

<TABLE>
<CAPTION>
                                   DECEMBER 31, 1999        DECEMBER 31, 1998
                                ON BALANCE  COMMITMENTS  ON BALANCE  COMMITMENTS
PROPERTY TYPE                     SHEET     TO PURCHASE    SHEET     TO PURCHASE
--------------------------------------------------------------------------------
<S>                             <C>         <C>          <C>         <C>
Apartments                       $ 54,118      $ --       $ 59,019      $ --
Department/retail stores           49,810        --         54,018       624
Office buildings                   22,090        --         23,902        --
Industrial buildings               16,938        --         18,590        33
Nursing/retirement                  5,058        --          5,153        --
Medical buildings                   7,248        --          7,416        --
Hotels/motels                          --        --            237        --
--------------------------------------------------------------------------------
                                  155,262        --        168,335       657
Less allowance for losses           1,200        --          1,500        --
--------------------------------------------------------------------------------
                                 $154,062      $ --       $166,835      $657
--------------------------------------------------------------------------------
--------------------------------------------------------------------------------
</TABLE>

Mortgage loan fundings are restricted by state insurance regulatory authority to
80 percent or less of the market value of the real estate at the time of
origination of the loan. The Company holds the mortgage document, which gives it
the right to take possession of the property if the borrower fails to perform
according to the terms of the agreement. The fair value of the mortgage loans is
determined by a discounted cash flow analysis using mortgage interest rates
currently offered for mortgages of similar maturities. Commitments to purchase
mortgages are made in the ordinary course of business. The fair value of the
mortgage commitments is $nil.

At December 31, 1999 and 1998, the Company's recorded investment in impaired
loans was $nil and $1,268, with allowances of $nil and $300, respectively.
During 1999 and 1998, the average recorded investment in impaired loans was $nil
and $1,282, respectively.

The Company recognized $2, $123 and $126 of interest income related to impaired
loans for the years ended December 31, 1999, 1998 and 1997, respectively.

The following table presents changes in the allowance for investment losses
related to all loans:

<TABLE>
<CAPTION>
                                      1999    1998    1997
-----------------------------------------------------------
<S>                                  <C>     <C>     <C>
Balance, January 1                   $1,500  $1,500  $1,300
Provision (reduction) for
  investment losses                    (300)     --     200
-----------------------------------------------------------
Balance, December 31                 $1,200  $1,500  $1,500
-----------------------------------------------------------
-----------------------------------------------------------
</TABLE>

Net investment income for the years ended December 31 is summarized as follows:

<TABLE>
<CAPTION>
                                      1999      1998      1997
----------------------------------------------------------------
<S>                                  <C>      <C>       <C>
Interest on fixed maturities         $78,342  $ 85,164  $ 92,007
Interest on mortgage loans            12,895    14,599    14,228
Other investment income                4,764     3,365     1,715
Interest on cash equivalents             350        64        91
----------------------------------------------------------------
                                      96,351   103,192   108,041
Less investment expenses                 837     2,321     1,767
----------------------------------------------------------------
                                     $95,514  $100,871  $106,274
----------------------------------------------------------------
----------------------------------------------------------------
</TABLE>

--------------------------------------------------------------------------------

                                     IDS LIFE INSURANCE COMPANY OF NEW YORK F-13
<PAGE>
Net realized gains (losses) on investments for the years ended December 31 is
summarized as follows:

<TABLE>
<CAPTION>
                                      1999    1998    1997
-----------------------------------------------------------
<S>                                  <C>     <C>     <C>
Fixed maturities                     $1,086  $2,018  $  844
Mortgage loans                          300      --    (200)
Other investments                        --     145     (97)
-----------------------------------------------------------
                                     $1,386  $2,163  $  547
-----------------------------------------------------------
-----------------------------------------------------------
</TABLE>

Changes in net unrealized appreciation (depreciation) of investments for the
years ended December 31 are summarized as follows:

<TABLE>
<CAPTION>
                                       1999     1998     1997
--------------------------------------------------------------
<S>                                  <C>       <C>      <C>
Fixed maturities available for sale  $(40,706) $(3,347) $9,599
</TABLE>

3. INCOME TAXES

The Company qualifies as a life insurance company for federal income tax
purposes. As such, the Company is subject to the Internal Revenue Code
provisions applicable to life insurance companies.

The income tax expense (benefit) for the years ending December 31 consists of
the following:

<TABLE>
<CAPTION>
                                      1999     1998     1997
--------------------------------------------------------------
<S>                                  <C>      <C>      <C>
Federal income taxes:
Current                              $16,426  $20,192  $16,371
Deferred                               2,196   (2,369)    (960)
--------------------------------------------------------------
                                      18,622   17,823   15,411
State income taxes-current               619    1,275    1,060
--------------------------------------------------------------
Income tax expense                   $19,241  $19,098  $16,471
--------------------------------------------------------------
--------------------------------------------------------------
</TABLE>

Increases (decreases) to the income tax provision applicable to pretax income
based on the statutory rate are attributable to:

<TABLE>
<CAPTION>
                                 1999              1998              1997
                           PROVISION  RATE   PROVISION  RATE   PROVISION  RATE
-------------------------------------------------------------------------------
<S>                        <C>        <C>    <C>        <C>    <C>        <C>
Federal income taxes
  based on the statutory
  rate                      $20,148   35.0%   $19,406   35.0%   $16,677   35.0%
Increases (decreases) are
  attributable to:
Tax-excluded interest and
  dividend income              (509)  (0.9)      (660)  (1.2)      (569)  (1.2)
State tax, net of federal
  benefit                       402    0.7        829    1.5        689    1.4
Other, net                     (800)  (1.4)      (477)  (0.9)      (326)  (0.6)
-------------------------------------------------------------------------------
Total income taxes          $19,241   33.4%   $19,098   34.4%   $16,471   34.6%
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------
</TABLE>

A portion of life insurance company income earned prior to 1984 was not subject
to current taxation but was accumulated, for tax purposes, in a "policyholders'
surplus account." At December 31, 1999, the Company had a policyholders' surplus
account balance of $798. The policyholders' surplus account is only taxable if
dividends to the stockholder exceed the stockholder's surplus account or if the
Company is liquidated. Deferred income taxes of $279 have not been established
because no distributions of such amounts are contemplated.

--------------------------------------------------------------------------------

F-14      IDS LIFE INSURANCE COMPANY OF NEW YORK
<PAGE>
Significant components of the Company's deferred income tax assets and
liabilities as of December 31 are as follows:

<TABLE>
<CAPTION>
                                           1999     1998
----------------------------------------------------------
<S>                                       <C>      <C>
Deferred income tax assets:
Policy reserves                           $28,245  $29,318
Investments                                 6,980       --
Other                                       6,690    6,502
----------------------------------------------------------
Total deferred income tax assets           41,915   35,820
----------------------------------------------------------
----------------------------------------------------------
Deferred income tax liabilities:
Deferred policy acquisition costs          38,033   36,673
Investments                                    --    7,059
----------------------------------------------------------
Total deferred income tax liabilities      38,033   43,732
----------------------------------------------------------
Net deferred income tax assets
  (liabilities)                           $ 3,882  ($7,912)
----------------------------------------------------------
----------------------------------------------------------
</TABLE>

The Company is required to establish a valuation allowance for any portion of
the deferred income tax assets that management believes will not be realized. In
the opinion of management, it is more likely than not that the Company will
realize the benefit of the deferred tax assets and, therefore, no such valuation
allowance has been established.

4. STOCKHOLDER'S EQUITY

Retained earnings available for distribution as dividends to IDS Life are
limited to the Company's surplus as determined in accordance with accounting
practices prescribed by the New York Department of Insurance. All dividend
distributions must be approved by the New York Department of Insurance.
Statutory unassigned surplus aggregated $155,952 and $132,702 as of
December 31, 1999 and 1998, respectively (see Note 3 with respect to the income
tax effect of certain distributions and Note 11 for a reconciliation of net
income and stockholder's equity per the accompanying financial statements to
statutory net income and surplus).

BENEFIT PLANS

The Company participates in the American Express Company Retirement Plan which
covers all permanent employees age 21 and over who have met certain employment
requirements. Employer contributions to the plan are based on participants' age,
years of service and total compensation for the year. Funding of retirement
costs for this plan complies with the applicable minimum funding requirements
specified by ERISA. The Company's share of the total net periodic pension cost
was $27, $37 and $39 in 1999, 1998 and 1997, respectively.

The Company has a "Sales Benefit Plan" which is an unfunded, noncontributory
retirement plan for all eligible financial advisors. Total plan costs for 1999,
1998 and 1997, which are calculated on the basis of commission earnings of the
individual financial advisors, were $1,446, $1,480 and $1,965, respectively.
Such costs are included in deferred policy acquisition costs.

The Company also participates in defined contribution pension plans of American
Express Company which cover all employees who have met certain employment
requirements. Company contributions to the plans are a percent of either each
employee's eligible compensation or basic contributions. Costs of these plans
charged to operations in 1999, 1998 and 1997 were $218, $252 and $312,
respectively.

--------------------------------------------------------------------------------

                                     IDS LIFE INSURANCE COMPANY OF NEW YORK F-15
<PAGE>
The Company participates in defined benefit health care plans of AEFC that
provide health care and life insurance benefits to retired employees and retired
financial advisors. The plans include participant contributions and
service-related eligibility requirements. Upon retirement, such employees are
considered to have been employees of AEFC. Costs of these plans charged to
operations in 1999, 1998 and 1997 were $nil.

6. INCENTIVE PLAN AND RELATED PARTY OPERATING EXPENSES

The Company maintains a "Persistency Payment Plan." Under the terms of this
plan, financial advisors earn additional compensation based on the volume and
persistency of insurance sales. The total costs for the plan for 1999, 1998 and
1997 were $96, $140 and $1,490, respectively. Such costs are included in
deferred policy acquisition costs.

Charges by IDS Life and AEFC for the use of joint facilities, marketing services
and other services aggregated $13,042, $9,403 and $11,589 for 1999, 1998 and
1997, respectively. Certain of these costs are included in deferred policy
acquisition costs.

7. COMMITMENTS AND CONTINGENCIES

In January 2000, AEFC reached an agreement in principle to settle three
class-action lawsuits. The Company had been named as a co-defendant in one of
these lawsuits. It is expected the settlement will provide $215 million of
benefits to more than 2 million participants. The agreement in principle to
settle also provides for release by class members of all insurance and annuity
market conduct claims dating back to 1985 and is subject to a number of
contingencies including a definitive agreement and court approval. The portion
of the settlement allocated to the Company did not have a material impact on the
Company's financial position or results from operations.

At December 31, 1999 and 1998, traditional life insurance and universal
life-type insurance in force aggregated $5,448,451 and $4,941,727 respectively,
of which $272,276 and $248,280 were reinsured at the respective year ends.

In addition, the Company has a stop loss reinsurance agreement with IDS Life
covering ordinary life benefits. IDS Life agrees to pay all death benefits
incurred each year which exceed 125 percent of normal claims, where normal
claims are defined in the agreement as .095 percent of the mean retained life
insurance in force. Premiums ceded to IDS Life amounted to $150, $134 and $115
for the years ended December 31, 1999, 1998 and 1997, respectively. Claim
recoveries under the terms of this reinsurance agreement were $nil, $nil and
$963 in 1999, 1998 and 1997, respectively.

Premiums ceded to reinsurers other than IDS Life amounted to $2,873, $2,178 and
$1,583 for the years ended December 31, 1999, 1998 and 1997, respectively. Claim
recoveries from reinsurers other than IDS Life amounted to $473, $228 and $1,366
for the years ended December 31, 1999, 1998 and 1997, respectively.

Reinsurance contracts do not relieve the Company from its primary obligations to
policyholders.

The Company has an agreement to assume a block of extended term life insurance
business. The amount of insurance in force related to this agreement was
$237,038 and $267,806 at December 31, 1999 and 1998, respectively. The
accompanying statement of income includes premiums of $nil for the years ended
December 31, 1999, 1998 and 1997, and decreases in liabilities for future policy
benefits of $1,277, $1,742 and $1,889 related to this agreement for the years
ended December 31, 1999, 1998 and 1997, respectively.

--------------------------------------------------------------------------------

F-16      IDS LIFE INSURANCE COMPANY OF NEW YORK
<PAGE>
8. LINES OF CREDIT

The Company has an available line of credit with AEFC aggregating $25,000. The
interest rate for any borrowing is established by reference to various indicies
plus 20 to 45 basis points depending on the term. There were no borrowings
outstanding under this agreement at December 31, 1999 or 1998.

9. DERIVATIVE FINANCIAL INSTRUMENTS

The Company enters into transactions involving derivative financial instruments
to manage its exposure to interest rate risk, including hedging specific
transactions. The Company does not hold derivative instruments for trading
purposes. The Company manages risks associated with these instruments as
described below.

Market risk is the possibility that the value of the derivative financial
instruments will change due to fluctuations in a factor from which the
instrument derives its value, primarily an interest rate. The Company is not
impacted by market risk related to derivatives held for non-trading purposes
beyond that inherent in cash market transactions. Derivatives are largely used
to manage risk and, therefore, the cash flow and income effects of the
derivatives are inverse to the effects of the underlying transactions.

Credit risk is the possibility that the counterparty will not fulfill the terms
of the contract. The Company monitors credit risk related to derivative
financial instruments through established approval procedures, including setting
concentration limits by counterparty and industry, and requiring collateral,
where appropriate. The Company's counterpart is rated A or better by Moody's and
Standard & Poor's.

Credit risk related to interest rate caps is measured by replacement cost of the
contracts. The replacement cost represents the fair value of the instruments.

The notional or contract amount of a derivative financial instrument is
generally used to calculate the cash flows that are received or paid over the
life of the agreement. Notional amounts are not recorded on the balance sheet.
Notional amounts far exceed the related credit exposure.

The Company's holdings of derivative financial instruments are as follows:

<TABLE>
<CAPTION>
                                           NOTIONAL    CARRYING      FAIR     TOTAL CREDIT
DECEMBER 31, 1999                           AMOUNT      AMOUNT      VALUE       EXPOSURE
------------------------------------------------------------------------------------------
<S>                                       <C>         <C>         <C>         <C>
Assets:
  Interest rate caps                       $200,000      $ --        $ --         $ --
------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------
</TABLE>

<TABLE>
<CAPTION>
DECEMBER 31, 1998
------------------------------------------------------------------------------------------
<S>                                       <C>         <C>         <C>         <C>
Assets:
  Interest rate caps                       $200,000      $566        $ 2          $ 2
------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------
</TABLE>

The fair values of derivative financial instruments are based on market values,
dealer quotes or pricing models. The interest rate caps expire in the year 2000.

Interest rate caps are used to manage the Company's exposure to interest rate
risk. These instruments are used primarily to protect the margin between
interest rates earned on investments and the interest rates credited to related
annuity contract holders.

--------------------------------------------------------------------------------

                                     IDS LIFE INSURANCE COMPANY OF NEW YORK F-17
<PAGE>
10. FAIR VALUES OF FINANCIAL INSTRUMENTS

The Company discloses fair value information for most on- and off-balance sheet
financial instruments for which it is practicable to estimate that value. Fair
values of life insurance obligations, receivables and all non-financial
instruments, such as deferred acquisition costs, are excluded. Off-balance sheet
intangible assets, such as the value of the field force, are also excluded.
Management believes the value of excluded assets and liabilities is significant.
The fair value of the Company, therefore, cannot be estimated by aggregating the
amounts presented.

<TABLE>
<CAPTION>
                                         1999                    1998
                                 CARRYING      FAIR      CARRYING      FAIR
FINANCIAL ASSETS                  AMOUNT      VALUE       AMOUNT      VALUE
------------------------------------------------------------------------------
<S>                             <C>         <C>         <C>         <C>
Investments:
  Fixed maturities (Note 2):
    Held to maturity            $  434,343  $  432,004  $  473,592  $  503,909
    Available for sale             555,574     555,574     578,591     578,591
  Mortgage loans on real
    estate (Note 2)                154,062     152,942     166,835     178,559
  Other:
    Derivative financial
      instruments (Note 9)              --          --         566           2
    Separate accounts assets
      (Note 1)                   1,957,703   1,957,703   1,491,679   1,491,679
</TABLE>

<TABLE>
<CAPTION>
                                         1999                    1998
                                 CARRYING      FAIR      CARRYING      FAIR
FINANCIAL LIABILITIES             AMOUNT      VALUE       AMOUNT      VALUE
------------------------------------------------------------------------------
<S>                             <C>         <C>         <C>         <C>
Future policy benefits for
  fixed annuities               $  732,752  $  715,213  $  788,780  $  765,430
Separate account liabilities     1,722,028   1,668,067   1,355,430   1,302,422
</TABLE>

At December 31, 1999 and 1998, the carrying amount and fair value of future
policy benefits for fixed annuities exclude life insurance-related contracts
carried at $83,646 and $81,358, respectively, and policy loans of $5,594 and
$5,369, respectively. The fair value of these benefits is based on the status of
the annuities at December 31, 1999 and 1998. The fair value of deferred
annuities is estimated as the carrying amount less any surrender charges and
related loans. The fair value for annuities in non-life contingent payout status
is estimated as the present value of projected benefit payments at rates
appropriate for contracts issued in 1999 and 1998.

At December 31, 1999 and 1998, the fair value of liabilities related to separate
accounts is estimated as the carrying amount less applicable surrender charges
and less variable insurance contracts carried at $235,675 and $136,249,
respectively.

--------------------------------------------------------------------------------

F-18      IDS LIFE INSURANCE COMPANY OF NEW YORK
<PAGE>
11. STATUTORY INSURANCE ACCOUNTING PRACTICES

Reconciliations of net income for the years ended December 31 and stockholder's
equity at December 31, as shown in the accompanying financial statements, to
that determined using statutory accounting practices are as follows:

<TABLE>
<CAPTION>
                                       1999      1998      1997
-----------------------------------------------------------------
<S>                                  <C>       <C>       <C>
Net income, per accompanying
  financial statements               $ 38,324  $ 36,348  $ 31,178
Deferred policy acquisition costs      (6,015)   (2,841)   (7,432)
Adjustments of future policy
  benefit liabilities                  (4,615)   (6,199)   (4,928)
Deferred income tax benefit             2,196    (2,369)     (960)
Provision for losses on investments      (161)      862       296
IMR gain/loss transfer and
  amortization                           (154)   (1,451)     (119)
Adjustment to separate account
  reserves                              5,498     2,767    10,267
Other, net                                766      (350)      430
-----------------------------------------------------------------
Net income, on basis of statutory
  accounting practices               $ 35,839  $ 26,767  $ 28,732
-----------------------------------------------------------------
-----------------------------------------------------------------
Stockholder's equity, per
  accompanying financial statements  $279,810  $279,466  $257,279
Deferred policy acquisition costs    (136,229) (129,477) (126,614)
Adjustments of future policy
  benefit liabilities                   2,845     4,697     9,452
Deferred income taxes                  (3,881)    7,912    11,445
Asset valuation reserve               (16,164)  (15,516)  (16,698)
Adjustments of separate account
  liabilities                          61,721    56,223    53,456
Adjustments of investments to
  amortized cost                       23,440   (17,266)  (20,613)
Premiums due, deferred and advance      1,485     1,381     1,237
Deferred revenue liability              3,021     2,482     1,941
Allowance for losses                    1,200     1,500     1,645
Non-admitted assets                      (421)     (450)     (552)
Interest maintenance reserve           (3,155)   (3,001)   (1,551)
Other, net                             (5,416)   (2,915)   (1,463)
-----------------------------------------------------------------
Stockholder's equity, on basis of
  statutory accounting practices     $208,256  $185,036  $168,963
-----------------------------------------------------------------
-----------------------------------------------------------------
</TABLE>

12. YEAR 2000 (UNAUDITED)

The Year 2000 issue is the result of computer programs having been written using
two digits rather than four to define a year. Any programs that have
time-sensitive software may recognize a date using "00" as the year 1900 rather
than 2000. This could result in the failure of major systems or miscalculations,
which could have a material impact on the operations of the Company. All of the
major systems used by the Company are maintained by AEFC and are utilized by
multiple subsidiaries and affiliates of AEFC. The Company's businesses are
heavily dependent upon AEFC's computer systems and have significant interaction
with systems of third parties.

A comprehensive review of AEFC's computer systems and business processes,
including those specific to the Company, was conducted to identify the major
systems that could be affected by the Year 2000 issue. Steps were taken to
resolve potential problems including modification to existing software and the
purchase of new software. As of December 31, 1999, AEFC had completed its
program of corrective measures on its internal systems and applications,
including Year 2000 compliance testing. As of December 31, 1999, AEFC had also
completed an evaluation of the Year 2000 readiness of other third parties whose
system failures could have an impact on the Company's operations.

--------------------------------------------------------------------------------

                                     IDS LIFE INSURANCE COMPANY OF NEW YORK F-19
<PAGE>
AEFC's Year 2000 project also included establishing Year 2000 contingency plans
for all key business units. Business continuation plans, which address business
continuation in the event of a system disruption, are in place for all key
business units. At December 31, 1999, these plans had been amended to include
specific Year 2000 considerations.

In assessing its Year 2000 initiatives and the results of actual production
since January 1, 2000, management believes no material adverse consequences were
experienced, and there was no material effect on the Company's business, results
of operations, or financial condition as a result of the Year 2000 issue.

--------------------------------------------------------------------------------

F-20      IDS LIFE INSURANCE COMPANY OF NEW YORK


<PAGE>

PART C.

Item 24. Financial Statements and Exhibits

(a)      Financial statements included in Part B of this Registration Statement:

         IDS Life Insurance Company of New York:
         Balance sheets as of Dec. 31, 1999 and 1998.
         Statements of Income for years ended Dec. 31, 1999, 1998, and 1997.
         Statements of Stockholder's Equity, for years ended Dec. 31, 1999,
         1998, and 1997.
         Statements of Cash Flows for years ended Dec. 31, 1999, 1998, and 1997.
         Notes to Financial Statements.
         Report of Independent Auditors dated March 17, 2000.

(b)      Exhibits:

1.1      Consent  in  writing  in  Lieu  of  Meeting  of IDS  Life  of New  York
         establishing  the  IDS  Life of New  York  Flexible  Portfolio  Annuity
         Account  dated April 17,  1996,  filed  electronically  as Exhibit 1 to
         Registrant's   Initial   Registration   Statement   No.   333-03867  is
         incorporated herein by reference.

1.2      Consent  in  writing  in  Lieu  of  Meeting  of IDS  Life  of New  York
         establishing  105 additional  subaccounts  within the separate  account
         dated  November  19,  1999  filed  electronically  as  Exhibit  1.2  to
         Registrant's Initial  Registration  Statement No. 333-91691 filed on or
         about Nov. 29, 1999, is incorporated herein by reference.

1.3      Resolution  of  the  Board  of  Directors  of  IDS  Life  of  New  York
         establishing  86 additional  subaccounts  within the separate  account,
         dated June 27, 2000 is filed electronically herewith.

2        Not applicable.

3.       Not applicable.

4.1      Form of Deferred Annuity Contract to be filed by amendment.

5.       Form of Variable Annuity Application to be filed by amendment.

6.1      Certificate  of  Incorporation  of IDS Life dated July 24, 1957,  filed
         electronically  as Exhibit  6.1 to  Registrant's  Initial  Registration
         Statement No. 33-62407 is incorporated herein by reference.

6.2      Copy of Amended  By-Laws of IDS Life of New York dated May 1992,  filed
         electronically  as Exhibit  6.2 to  Registrant's  Initial  Registration
         Statement No. 333-03867 is incorporated herein by reference.

7.       Not applicable.

8.       Participation Agreements to be filed by amendment.

9.       Opinion  of  counsel  and  consent  to its use as the  legality  of the
         securities being registered, filed electronically herewith.

10.      Consent of Independent Auditors, filed electronically herewith.

11.      None.

12.      Not applicable.

<PAGE>

13.      Copy of schedule for computation of each performance quotation provided
         in the  Registration  Statement  in response to Item 21, to be filed by
         Amendment.

14.      Not applicable.

15.      Power of Attorney to sign this  Registration  Statement dated April 14,
         1999, filed  electronically as Exhibit 14 to  Post-Effective  Amendment
         No. 3 to Registration Statement No. 333-03867,  filed on or about April
         28, 1999, is incorporated herein by reference.

Item 25. Directors and Officers of the Depositor (IDS Life Insurance Company of
         New York)
--------------------------------------------------------------------------------
<TABLE>
<CAPTION>
<S>                                   <C>                                       <C>

Name                                  Principal Business Address                Positions and Offices with Depositor
------------------------------------- ----------------------------------------- -------------------------------------

Timothy V. Bechtold                   200 AXP Financial Center                  Director and President
                                      Minneapolis, MN  55474

Maureen A. Buckley                    20 Madison Ave. Extension                 Director, Vice President, Chief
                                      Albany, NY                                     Operating Officer and Consumer
                                                                                     Affairs Officer

Rodney P. Burwell                     Xerxes Corporation                        Director
                                      790 Xerxes Ave. So.
                                      Minneapolis, MN

John R. Cattau                        20 Madison Ave. Extension                 Director
                                      Albany, NY

James E. Choat                        200 AXP Financial Center                  Executive Vice President,
                                      Minneapolis, MN  55474                         Institutional Products Group

Robert R. Grew                        20 Madison Avenue Extension               Director
                                      Albany, NY

Lorraine R. Hart                      200 AXP Financial Center                  Vice President, Investments
                                      Minneapolis, MN  55474

Jeffrey S. Horton                     200 AXP Financial Center                  Vice President and Treasurer
                                      Minneapolis, MN  55474

Jean B. Keffeler                      3424 Zenith Ave. So.                      Director
                                      Minneapolis, MN

Richard W. Kling                      200 AXP Financial Center                  Director and Chairman of the Board
                                      Minneapolis, MN  55474

Bruce A. Kohn                         200 AXP Financial Center                  Counsel and Assistant Secretary
                                      Minneapolis, MN  55474

Eric L. Marhoun                       200 AXP Financial Center                  General Counsel and Secretary
                                      Minneapolis, MN  55474

Thomas R. McBurney                    1700 Foshay Tower                         Director
                                      821 Marquette Ave.
                                      Minneapolis, MN

Mary Ellyn Minenko                    200 AXP Financial Center                  Counsel and Assistant Secretary
                                      Minneapolis, MN  55474
<PAGE>

Edward J. Muhl                        200 AXP Financial Center                  Director
                                      Minneapolis, MN  55474

Thomas V. Nicolosi                    Suite 220                                 Director
                                      500 Mamaroneck Avenue
                                      Harrison, NY  10528

Stephen P. Norman                     World Financial Center                    Director
                                      New York, NY

Richard M. Starr                      20 Madison Avenue Extension               Director
                                      Albany, NY

William A. Stoltzmann                 200 AXP Financial Center                  Counsel and Assistant Secretary
                                      Minneapolis, MN  55474

Philip C. Wentzel                     200 AXP Financial Center                  Vice President and Controller, Risk
                                      Minneapolis, MN  55474                         Management

Michael R. Woodward                   20 Madison Avenue Extension               Director
                                      Albany, NY
</TABLE>

Item 26. Persons Controlled by or Under Common Control with the Depositor or
         Registrant

         IDS Life Insurance Company of New York is a wholly-owned  subsidiary of
         IDS Life  Insurance  Company  which  is a  wholly-owned  subsidiary  of
         American Express  Financial  Corporation.  American  Express  Financial
         Corporation is a wholly-owned  subsidiary of American  Express  Company
         (American Express)

         The following list includes the names of major subsidiaries of American
         Express.
<TABLE>
<CAPTION>
<S>                                                                                     <C>
                                                                                        Jurisdiction of
Name of Subsidiary                                                                      Incorporation

I. Travel Related Services

     American Express Travel Related Services Company, Inc.                             New York

II. International Banking Services

     American Express Bank Ltd.                                                         Connecticut

III. Companies engaged in Financial Services

     Advisory Capital Partners LLC                                                      Delaware
     Advisory Capital Strategies Group Inc.                                             Minnesota
     American Centurion Life Assurance Company                                          New York
     American Enterprise Investment Services Inc.                                       Minnesota
     American Enterprise Life Insurance Company                                         Indiana
     American Express Asset Management Group Inc.                                       Minnesota
     American Express Asset Management International Inc.                               Delaware
     American Express Asset Management International (Japan) Ltd.                       Japan
     American Express Asset Management Ltd.                                             England
     American Express Client Service Corporation                                        Minnesota
     American Express Corporation                                                       Delaware
     American Express Financial Advisors Inc.                                           Delaware

<PAGE>


     American Express Financial Advisors Japan Inc.                                     Delaware
     American Express Financial Corporation                                             Delaware
     American Express Insurance Agency of Arizona Inc.                                  Arizona
     American Express Insurance Agency of Idaho Inc.                                    Idaho
     American Express Insurance Agency of Nevada Inc.                                   Nevada
     American Express Insurance Agency of Oregon Inc.                                   Oregon
     American Express Minnesota Foundation                                              Minnesota
     American Express Property Casualty Insurance Agency of Kentucky Inc.               Kentucky
     American Express Property Casualty Insurance Agency of Maryland Inc.               Maryland
     American Express Property Casualty Insurance Agency of Mississippi Inc.            Mississippi
     American Express Property Casualty Insurance Agency of Pennsylvania Inc.           Pennsylvania
     American Express Trust Company                                                     Minnesota
     American Partners Life Insurance Company                                           Arizona
     IDS Cable Corporation                                                              Minnesota
     IDS Cable II Corporation                                                           Minnesota
     IDS Capital Holdings Inc.                                                          Minnesota
     IDS Certificate Company                                                            Delaware
     IDS Futures Brokerage Group                                                        Minnesota
     IDS Futures Corporation                                                            Minnesota
     IDS Insurance Agency of Alabama Inc.                                               Alabama
     IDS Insurance Agency of Arkansas Inc.                                              Arkansas
     IDS Insurance Agency of Massachusetts Inc.                                         Massachusetts
     IDS Insurance Agency of Mississippi Ltd.                                           Mississippi
     IDS Insurance Agency of New Mexico Inc.                                            New Mexico
     IDS Insurance Agency of North Carolina Inc.                                        North Carolina
     IDS Insurance Agency of Ohio Inc.                                                  Ohio
     IDS Insurance Agency of Texas Inc.                                                 Texas
     IDS Insurance Agency of Utah Inc.                                                  Utah
     IDS Insurance Agency of Wyoming Inc.                                               Wyoming
     IDS Life Insurance Company                                                         Minnesota
     IDS Life Insurance Company of New York                                             New York
     IDS Management Corporation                                                         Minnesota
     IDS Partnership Services Corporation                                               Minnesota
     IDS Plan Services of California, Inc.                                              Minnesota
     IDS Property Casualty Insurance Company                                            Wisconsin
     IDS Real Estate Services, Inc.                                                     Delaware
     IDS Realty Corporation                                                             Minnesota
     IDS Sales Support Inc.                                                             Minnesota
     Investors Syndicate Development Corp.                                              Nevada
     Public Employee Payment Company                                                    Minnesota
</TABLE>

Item 27. Number of Contractowners

         Not applicable.

<PAGE>

Item 28. Indemnification

         The By-Laws of the depositor provide that it shall indemnify any person
         who was or is a party or is threatened to be made a party, by reason of
         the fact that he is or was a  director,  officer,  employee or agent of
         this  Corporation,  or is or  was  serving  at  the  direction  of  the
         Corporation  as a  director,  officer,  employee  or agent  of  another
         corporation,  partnership, joint venture, trust or other enterprise, to
         any  threatened,  pending  or  completed  action,  suit or  proceeding,
         wherever  brought,  to the fullest extent  permitted by the laws of the
         State of Minnesota, as now existing or hereafter amended, provided that
         this Article shall not indemnify or protect any such director, officer,
         employee  or agent  against any  liability  to the  Corporation  or its
         security  holders to which he would  otherwise  be subject by reason of
         willful misfeasance, bad faith, or gross negligence, in the performance
         of his duties or by reason of his reckless disregard of his obligations
         and duties.

         Insofar as  indemnification  for liability arising under the Securities
         Act of 1933 may be  permitted to  director,  officers  and  controlling
         persons of the  registrant  pursuant to the  foregoing  provisions,  or
         otherwise,  the  registrant has been advised that in the opinion of the
         Securities  and Exchange  Commission  such  indemnification  is against
         public policy as expressed in the Act and is, therefore, unenforceable.
         In the event that a claim for indemnification  against such liabilities
         (other than the payment by the registrant of expenses  incurred or paid
         by a director,  officer or controlling  person of the registrant in the
         successful  defense of any action,  suit or  proceeding) is asserted by
         such  director,  officer or controlling  person in connection  with the
         securities being registered, the registrant will, unless in the opinion
         of its counsel the matter has been  settled by  controlling  precedent,
         submit to a court of appropriate jurisdiction the question whether such
         indemnification  by it is against public policy as expressed in the Act
         and will be governed by the final adjudication of such issue.

Item 29. Principal Underwriters.

(a)      American Express Financial  Advisors acts as principal  underwriter for
         the following investment companies:

         AXP Bond Fund,  Inc.; AXP California  Tax-Exempt  Trust;  AXP Discovery
         Fund,  Inc.; AXP Equity Select Fund, Inc.; AXP Extra Income Fund, Inc.;
         AXP Federal  Income Fund,  Inc.;  AXP Global  Series,  Inc.; AXP Growth
         Series,  Inc.; AXP High Yield Tax-Exempt Fund, Inc.; AXP  International
         Fund, Inc.; AXP Investment Series,  Inc.; AXP Managed Series, Inc.; AXP
         Market Advantage Series,  Inc.; AXP Money Market Series,  Inc.; AXP New
         Dimensions  Fund, Inc.; AXP Precious Metals Fund, Inc.; AXP Progressive
         Fund,  Inc.; AXP Selective Fund,  Inc.; AXP Special  Tax-Exempt  Series
         Trust; AXP Stock Fund, Inc.; AXP Strategy Series,  Inc.; AXP Tax-Exempt
         Series, Inc.; AXP Tax-Free Money Fund, Inc.; AXP Utilities Income Fund,
         Inc.,  Growth Trust;  Growth and Income Trust;  Income Trust;  Tax-Free
         Income Trust; World Trust; IDS Certificate  Company;  Strategist Income
         Fund, Inc.;  Strategist Growth Fund, Inc.; Strategist Growth and Income
         Fund, Inc.;  Strategist World Fund, Inc. and Strategist Tax-Free Income
         Fund, Inc.


(b) As to each director, officer or partner of the principal underwriter:


Name and Principal Business Address   Position and Offices with
                                      Underwriter
------------------------------------- -----------------------------------

Ronald. G. Abrahamson                 Vice President - Business
200 AXP Financial Center              Transformation
Minneapolis, MN  55474

Douglas A. Alger                      Senior Vice President - Human
200 AXP Financial Center              Resources
Minneapolis, MN  55474

<PAGE>

Peter J. Anderson                     Senior Vice President -
200 AXP Financial Center              Investment Operations
Minneapolis, MN  55474

Ward D. Armstrong                     Senior Vice President -
200 AXP Financial Center              Retirement Services
Minneapolis, MN  55474

John M. Baker                         Vice President - Plan Sponsor
200 AXP Financial Center              Services
Minneapolis, MN  55474

Joseph M. Barsky, III                 Vice President - Mutual Fund
200 AXP Financial Center              Equities
Minneapolis, MN  55474

Timothy V. Bechtold                   Vice President - Risk Management
200 AXP Financial Center              Products
Minneapolis, MN  55474

John D. Begley                        Group Vice President -
Suite 100                             Ohio/Indiana
7760 Olentangy River Rd.
Columbus, OH  43235

Brent L. Bisson                       Group Vice President - Los
Suite 900                             Angeles Metro
E. Westside Twr
11835 West Olympic Blvd.
Los Angeles, CA  90064

John C. Boeder                        Vice President - Nonproprietary
200 AXP Financial Center              Products
Minneapolis, MN  55474

Walter K. Booker                      Group Vice President - New Jersey
200 AXP Financial Center
Minneapolis, MN  55474

Bruce J. Bordelon                     Group Vice President - San
1333 N. California Blvd., Suite 200   Francisco Bay Area
Walnut Creek, CA  94596

Charles R. Branch                     Group Vice President - Northwest
Suite 200
West 111 North River Dr.
Spokane, WA  99201

<PAGE>

Douglas W. Brewers                    Vice President - Sales Support
200 AXP Financial Center
Minneapolis, MN  55474

Karl J. Breyer                        Corporate Senior Vice President
200 AXP Financial Center
Minneapolis, MN  55474

Cynthia M. Carlson                    Vice President - American Express
200 AXP Financial Center              Securities Services
Minneapolis, MN  55474

<PAGE>


Mark W. Carter                        Senior Vice President and Chief
200 AXP Financial Center              Marketing Officer
Minneapolis, MN  55474

James E. Choat                        Senior Vice President - Third
200 AXP Financial Center              Party Distribution
Minneapolis, MN  55474


<PAGE>

Kenneth J. Ciak                       Vice President and General
IDS Property Casualty                 Manager - IDS Property Casualty
1400 Lombardi Avenue
Green Bay, WI  54304

Paul A. Connolly                      Vice President - Advisor
200 AXP Financial Center              Staffing, Training and Support
Minneapolis, MN  55474

Henry J. Cormier                      Group Vice President - Connecticut
Commerce Center One
333 East River Drive
East Hartford, CT  06108

John M. Crawford                      Group Vice President -
Suite 200                             Arkansas/Springfield/Memphis
10800 Financial Ctr Pkwy
Little Rock, AR  72211

Kevin F. Crowe                        Group Vice President -
Suite 312                             Carolinas/Eastern Georgia
7300 Carmel Executive Pk
Charlotte, NC  28226

Colleen Curran                        Vice President and Assistant
200 AXP Financial Center              General Counsel
Minneapolis, MN  55474

Luz Maria Davis                       Vice President - Communications
200 AXP Financial Center
Minneapolis, MN  55474

Arthur E. DeLorenzo                   Group Vice President - Upstate
4 Atrium Drive, #100                  New York
Albany, NY  12205

Scott M. DiGiammarino                 Group Vice President -
Suite 500                             Washington/Baltimore
8045 Leesburg Pike
Vienna, VA  22182

Bradford L. Drew                      Group Vice President - Eastern
Two Datran Center                     Florida
Penthouse One B
9130 S. Dadeland Blvd.
Miami, FL  33156

Douglas K. Dunning                    Vice President - Assured Assets
200 AXP Financial Center              Product Development and Management
Minneapolis, MN  55474

<PAGE>

James P. Egge                         Group Vice President - Western
4305 South Louise, Suite 202          Iowa, Nebraska, Dakotas
Sioux Falls, SD  57103

Gordon L. Eid                         Senior Vice President, General
200 AXP Financial Center              Counsel and Chief Compliance
Minneapolis, MN  55474                Officer

<PAGE>

Robert M. Elconin                     Vice President - Government
200 AXP Financial Center              Relations
Minneapolis, MN  55474

Phillip W. Evans,                     Group Vice President - Rocky
Suite 600                             Mountain
6985 Union Park Center
Midvale, UT  84047-4177

Gordon M. Fines                       Vice President - Mutual Fund
200 AXP Financial Center              Equity Investments
Minneapolis, MN  55474

Douglas L. Forsberg                   Vice President - International
200 AXP Financial Center
Minneapolis, MN  55474

Jeffrey P. Fox                        Vice President and Corporate
200 AXP Financial Center              Controller
Minneapolis, MN  55474

William P. Fritz                      Group Vice President - Gateway
Suite 160
12855 Flushing Meadows Dr.
St. Louis, MO  63131

Carl W. Gans                          Group Vice President - Twin City
8500 Tower Suite 1770                 Metro
8500 Normandale Lake Blvd.
Bloomington, MN  55437

Peter A. Gallus                       Vice President-Investment
200 AXP Financial Center              Administration
Minneapolis, MN  55474

Derek G. Gledhill                     Vice President - Integrated
200 AXP Financial Center              Financial Services Field
Minneapolis, MN  55474                Implementation

David A. Hammer                       Vice President and Marketing
200 AXP Financial Center              Controller
Minneapolis, MN  55474

Teresa A. Hanratty                    Senior Vice President-Field
Suites 6&7                            Management
169 South River Road
Bedford, NH  03110

Robert L. Harden                      Group Vice President - Boston
Two Constitution Plaza                Metro
Boston, MA  02129

Lorraine R. Hart                      Vice President - Insurance
200 AXP Financial Center              Investments
Minneapolis, MN  55474

<PAGE>

Scott A. Hawkinson                    Vice President and Controller -
200 AXP Financial Center              Private Client Group
Minneapolis, MN  55474

Brian M. Heath                        Senior Vice President and General
Suite 150                             Sales Manager
801 E. Campbell Road
Richardson, TX  75081

Janis K. Heaney                       Vice President - Incentive
200 AXP Financial Center              Management
Minneapolis, MN  55474

Jon E. Hjelm                          Group Vice President - Rhode
310 Southbridge Street                Island/Central - Western
Auburn, MA  01501                     Massachusetts

David J. Hockenberry                  Group Vice President - Tennessee
30 Burton Hills Blvd.                 Valley
Suite 175
Nashville, TN  37215

Jeffrey S. Horton                     Vice President and Treasurer
200 AXP Financial Center
Minneapolis, MN  55474

David R. Hubers                       Chairman, President and Chief
200 AXP Financial Center              Executive Officer
Minneapolis, MN  55474

Debra A. Hutchinson                   Vice President - Relationship
200 AXP Financial Center              Leader
Minneapolis, MN  55474

James M. Jensen                       Vice President and
200 AXP Financial Center              Controller-Advice and Retail
Minneapolis, MN  55474                Distribution Group

Marietta L. Johns                     Senior Vice President - Field
200 AXP Financial Center              Management
Minneapolis, MN  55474

Nancy E. Jones                        Vice President - Business
200 AXP Financial Center              Development
Minneapolis, MN  55474

Ora J. Kaine                          Vice President - Financial
200 AXP Financial Center              Advisory Services
Minneapolis, MN  55474

Linda B. Keene                        Vice President - Market
200 AXP Financial Center              Development
Minneapolis, MN  55474

G. Michael Kennedy                    Vice President - Senior Portfolio
200 AXP Financial Center              Manager
Minneapolis, MN  55474

<PAGE>

Richard W. Kling                      Senior Vice President - Products
200 AXP Financial Center
Minneapolis, MN  55474

John M. Knight                        Vice President - Investment
200 AXP Financial Center              Accounting
Minneapolis, MN  55474

Paul F. Kolkman                       Vice President - Actuarial Finance
200 AXP Financial Center
Minneapolis, MN  55474

Claire Kolmodin                       Vice President - Service Quality
200 AXP Financial Center
Minneapolis, MN  55474

David S. Kreager                      Group Vice President - Greater
Suite 108                             Michigan
Trestle Bridge V
5126 Lovers Lane
Kalamazoo, MI  49002

Steven C. Kumagai                     Director and Senior Vice
200 AXP Financial Center              President-Direct and Interactive
Minneapolis, MN  55474                Group

Mitre Kutanovski                      Group Vice President - Chicago
Suite 680                             Metro
8585 Broadway
Merrillville, IN  48410

Kurt A. Larson                        Vice President - Senior Portfolio
200 AXP Financial Center              Manager
Minneapolis, MN  55474

Lori J. Larson                        Vice President - Brokerage and
200 AXP Financial Center              Direct Services
Minneapolis, MN  55474

Daniel E. Laufenberg                  Vice President and Chief U.S.
200 AXP Financial Center              Economist
Minneapolis, MN  55474

Jane W. Lee                           Vice President - New Business
200 AXP Financial Center              Development and Marketing
Minneapolis, MN  55474

Peter A. Lefferts                     Senior Vice President - Corporate
200 AXP Financial Center              Strategy and Development
Minneapolis, MN  55474

Douglas A. Lennick                    Director and Executive Vice
200 AXP Financial Center              President - Private Client Group
Minneapolis, MN  55474

Fred A. Mandell                       Vice President - Field Marketing
200 AXP Financial Center              Readiness
Minneapolis, MN  55474

<PAGE>

Daniel E. Martin                      Group Vice President - Pittsburgh
Suite 650                             Metro
5700 Corporate Drive
Pittsburgh, PA  15237

Timothy J. Masek                      Vice President and Director of
200 AXP Financial Center              Global Research
Minneapolis, MN  55474

Sarah A. Mealey                       Vice President - Mutual Funds
200 AXP Financial Center
Minneapolis, MN  55474

Paula R. Meyer                        Vice President - Assured Assets
200 AXP Financial Center
Minneapolis, MN  55474

William P. Miller                     Vice President and Senior
200 AXP Financial Center              Portfolio Manager
Minneapolis, MN  55474

Shashank B. Modak                     Vice President - Technology Leader
200 AXP Financial Center
Minneapolis, MN  55474

Pamela J. Moret                       Vice President - Variable Assets
200 AXP Financial Center
Minneapolis, MN  55474

Barry J. Murphy                       Senior Vice President - Client
200 AXP Financial Center              Service
Minneapolis, MN  55474

Mary Owens Neal                       Vice President-Consumer Marketing
200 AXP Financial Center
Minneapolis, MN  55474

Thomas V. Nicolosi                    Group Vice President - New York
Suite 220                             Metro Area
500 Mamaroneck Avenue
Harrison, NY  10528

Michael J. O'Keefe                    Vice President - Advisory
200 AXP Financial Center              Business Systems
Minneapolis, MN  55474

James R. Palmer                       Vice President - Taxes
200 AXP Financial Center
Minneapolis, MN  55474

Marc A. Parker                        Group Vice President -
10200 SW Greenburg Road               Portland/Eugene
Suite 110
Portland, OR  97223

Carla P. Pavone                       Vice President-Compensation
200 AXP Financial Center              Services and ARD Product
Minneapolis, MN  55474                Distribution

<PAGE>

Thomas P. Perrine                     Senior Vice President - Group
200 AXP Financial Center              Relationship Leader/American
Minneapolis, MN  55474                Express Technologies Financial
                                      Services

Susan B. Plimpton                     Vice President - Marketing
200 AXP Financial Center              Services
Minneapolis, MN  55474

Larry M. Post                         Group Vice President -
One Tower Bridge                      Philadelphia Metro and Northern
100 Front Street, 8th Fl              New England
West Conshohocken, PA  19428

Ronald W. Powell                      Vice President and Assistant
200 AXP Financial Center              General Counsel
Minneapolis, MN  55474

Diana R. Prost                        Group Vice President -
3030 N.W. Expressway                  Kansas/Oklahoma
Suite 900
Oklahoma City, OK  73112

James M. Punch                        Vice President and Project
200 AXP Financial Center              Manager - Platform I Value
Minneapolis, MN  55474                Enhanced

Frederick C. Quirsfeld                Senior Vice President - Fixed
200 AXP Financial Center              Income
Minneapolis, MN  55474

Rollyn C. Renstrom                    Vice President - Corporate
200 AXP Financial Center              Planning and Analysis
Minneapolis, MN  55474

R. Daniel Richardson                  Group Vice President - Southern
Suite 800                             Texas
Arboretum Plaza One
9442 Capital of Texas Hwy. N
Austin, TX  78759

ReBecca K. Roloff                     Senior Vice President - Field
200 AXP Financial Center              Management and Financial Advisory
Minneapolis, MN  55474                Service

Stephen W. Roszell                    Senior Vice President -
200 AXP Financial Center              Institutional
Minneapolis, MN  55474

Max G. Roth                           Group Vice President -
Suite 201 S. IDS Ctr                  Wisconsin/Upper Michigan
1400 Lombardi Avenue
Green Bay, WI  54304

Erven A. Samsel                       Senior Vice President - Field
45 Braintree Hill Park                Management
Suite 402
Braintree, MA  02184

<PAGE>

Theresa M. Sapp                       Vice President - Relationship
200 AXP Financial Center              Leader
Minneapolis, MN  55474

Russell L. Scalfano                   Group Vice President -
Suite 201                             Illinois/Indiana/Kentucky
101 Plaza East Blvd.
Evansville, IN  47715

William G. Scholz                     Group Vice President -
Suite 205                             Arizona/Las Vegas
7333 E. Doubletree Ranch Rd
Scottsdale, AZ  85258

Stuart A. Sedlacek                    Senior Vice President and Chief
200 AXP Financial Center              Financial Officer
Minneapolis, MN  55474

Donald K. Shanks                      Vice President - Property Casualty
200 AXP Financial Center
Minneapolis, MN  55474

Judy P. Skoglund                      Vice President - Quality and
200 AXP Financial Center              Service Support
Minneapolis, MN  55474

James B. Solberg                      Group Vice President - Eastern
466 Westdale Mall                     Iowa Area
Cedar Rapids, IA  52404

Bridget Sperl                         Vice President - Geographic
200 AXP Financial Center              Service Teams
Minneapolis, MN  55474

Paul J. Stanislaw                     Group Vice President - Southern
Suite 1100                            California
Two Park Plaza
Irvine, CA  92714

Lisa A. Steffes                       Vice President - Marketing Offer
200 AXP Financial Center              Development
Minneapolis, MN  55474

Lois A. Stilwell                      Group Vice President - Outstate
Suite 433                             Minnesota Area/North
9900 East Bren Road                   Dakota/Western Wisconsin
Minnetonka, MN  55343

William A. Stoltzmann                 Vice President and Assistant
200 AXP Financial Center              General Counsel
Minneapolis, MN  55474

James J. Strauss                      Vice President and General Auditor
200 AXP Financial Center
Minneapolis, MN  55474

Jeffrey J. Stremcha                   Vice President - Information
200 AXP Financial Center              Resource Management/ISD
Minneapolis, MN  55474

<PAGE>

Barbara Stroup Stewart                Vice President - Channel
200 AXP Financial Center              Development
Minneapolis, MN  55474

Craig P. Taucher                      Group Vice President -
Suite 150                             Orlando/Jacksonville
4190 Belfort Road
Jacksonville, FL  32216

Neil G. Taylor                        Group Vice President -
Suite 425                             Seattle/Tacoma/Hawaii
101 Elliott Avenue West
Seattle, WA  98119

John R. Thomas                        Senior Vice President
200 AXP Financial Center
Minneapolis, MN  55474

Keith N. Tufte                        Vice President and Director of
200 AXP Financial Center              Equity Research
Minneapolis, MN  55474

Peter S. Velardi                      Group Vice President -
Suite 180                             Atlanta/Birmingham
1200 Ashwood Parkway
Atlanta, GA  30338

Charles F. Wachendorfer               Group Vice President - Detroit
Suite 100                             Metro
Stanford Plaza II
7979 East Tufts Ave. Pkwy
Denver, CO  80237

Donald F. Weaver                      Group Vice President - Greater
3500 Market Street, Suite 200         Pennsylvania
Camp Hill, PA  17011

Norman Weaver Jr.                     Senior Vice President - Alliance
1010 Main St., Suite 2B               Group
Huntington Beach, CA  92648

Michael L. Weiner                     Vice President - Tax Research and
200 AXP Financial Center              Audit
Minneapolis, MN  55474

Jeffry M. Welter                      Vice President - Equity and Fixed
200 AXP Financial Center              Income Trading
Minneapolis, MN  55474

Thomas L. White                       Group Vice President - Cleveland
Suite 200                             Metro
28601 Chagrin Blvd.
Woodmere, OH  44122

Eric S. Williams                      Group Vice President - Virginia
Suite 250
3951 Westerre Parkway
Richmond, VA  23233

<PAGE>


William J. Williams                   Group Vice President - Western
Two North Tamiami Trail               Florida
Suite 702
Sarasota, FL  34236

<PAGE>

Edwin M. Wistrand                     Vice President and Assistant
200 AXP Financial Center              General Counsel
Minneapolis, MN  55474

Michael D. Wolf                       Vice President - Senior Portfolio
200 AXP Financial Center              Manager
Minneapolis, MN  55474

Michael R. Woodward                   Senior Vice President - Field
32 Ellicott St.                       Management
Suite 100
Batavia, NY  14020

Rande L. Zellers                      Group Vice President-Gulf States
1 Galleria Blvd., Suite 1900
Metairie, LA  70001

Item 30. Location of Accounts and Records

         IDS Life Insurance Company of New York
         20 Madison Avenue Extension
         Albany, NY 12203

Item 31. Management Services

         Not applicable.

Item 32. Undertakings

(a)      Registrant  undertakes  to  file a  post-effective  amendment  to  this
         registration statement as frequently as is necessary to ensure that the
         audited  financial  statements in the registration  statement are never
         more  than 16 months  old for so long as  payments  under the  variable
         annuity contracts may be accepted.

(b)      Registrant  undertakes to include either (1) as part of any application
         to  purchase a  contract  offered  by the  prospectus,  a space that an
         applicant can check to request a Statement of  Additional  Information,
         or (2) a post  card or  similar  written  communication  affixed  to or
         included in the prospectus  that the applicant can remove to send for a
         Statement of Additional Information.

(c)      Registrant   undertakes   to  deliver  any   Statement  of   Additional
         Information and any financial  statements required to be made available
         under this Form promptly upon written or oral request.

(d)      Registrant  represents that it is relying upon the no-action  assurance
         given to the American Council of Life Insurance (pub.  avail.  Nov. 28,
         1988).Further,  Registrant  represents  that it has  complied  with the
         provisions of paragraphs (1)-(4) of that no-action letter.

(e)      The sponsoring  insurance company  represents that the fees and charges
         deducted  under the  contract,  in the  aggregate,  are  reasonable  in
         relation  to  the  services  rendered,  the  expenses  expected  to  be
         incurred, and the risks assumed by the insurance company.

<PAGE>

                                                SIGNATURES

As  required by the  Securities  Act of 1933 and the  Investment  Company Act of
1940, IDS Life Insurance  Company of New York, on behalf of the Registrant,  has
duly caused this  Registration  Statement to be signed on its behalf in the City
of Minneapolis, and State of Minnesota, on the 7th day of July, 2000.


         IDS LIFE OF NEW YORK VARIABLE ANNUITY ACCOUNT
         (formerly IDS Life of New York Flexible Portfolio Annuity Account)
         (Registrant)

         By IDS Life Insurance Company of New York
         (Sponsor)

         By /s/ Timothy V. Bechtold*
                Timothy V. Bechtold
                President

As required by the Securities Act of 1933, this Registration  Statement has been
signed by the following  persons in the capacities  indicated on the 7th day of
July, 2000.

/s/ Timothy V. Bechtold*                                /s/  Thomas R. McBurney*
Timothy V. Bechtold                                     Thomas R. McBurney
Director and President                                  Director

/s/ Maureen A. Buckley*                                 /s/ Edward J. Muhl*
Maureen A. Buckley                                      Edward J. Muhl
Director, Vice President, Chief Operating Officer,      Director
Consumer Affairs Officer and Claims Officer

/s/ Rodney P. Burwell*                                  /s/ Thomas V. Nicolosi*
Rodney P. Burwell                                       Thomas V. Nicolosi
Director                                                Director

/s/ John R. Cattau*                                     /s/ Stephen P. Norman*
John R. Cattau                                          Stephen P. Norman
Director                                                Director

/s/ Robert R. Grew*                                     /s/ Richard M. Starr*
Robert R. Grew                                          Richard M. Starr
Director                                                Director

/s/ Jeffrey S. Horton*                                  /s/ Philip C. Wentzel*
Jeffrey S. Horton                                       Philip C. Wentzel
Vice President and Treasurer                            Vice President and
                                                        Controller - Risk
                                                        Management

<PAGE>

/s/ Jean B. Keffeler*                                   /s/ Michael R. Woodward*
Jean B. Keffeler                                        Michael R. Woodward
Director                                                Director

/s/ Richard W. Kling*
Richard W. Kling
Director and Chairman of the Board


*Signed pursuant to Power of Attorney dated April 14, 1999, filed electronically
as Exhibit 14 to  Post-Effective  Amendment No. 3 to Registration  Statement No.
333-03867, is incorporated herein by reference.




By    /s/Mary Ellyn Minenko
         Mary Ellyn Minenko
         Vice President and Group Counsel


<PAGE>



CONTENTS OF PRE-EFFECTIVE AMENDMENT NO. 1

This Pre-Effective  Amendment  No. 1 is  comprised of the  following  papers and
documents:

The Cover Page.

Part A.

         The prospectus.

Part B.

         Statement of Additional Information.

         Financial Statements

Part C.

         Other Information.

         The signatures.

Exhibits.



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