RELIASTAR BANKERS SECURITY LIFE INSURANCE CO
N-8B-2, 1997-03-31
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                                 UNITED STATES
                       SECURITIES AND EXCHANGE COMMISSION
                             Washington, D. C. 20549


                                   FORM N-8B-2


                REGISTRATION STATEMENT OF UNIT INVESTMENT TRUSTS
                     WHICH ARE CURRENTLY ISSUING SECURITIES

         Pursuant to Section 8(b) of the Investment Company Act of 1940




                       RELIASTAR BANKERS SECURITY VARIABLE
                             LIFE SEPARATE ACCOUNT I
                         (Name of Unit Investment Trust)


               [ ]  Not the Issuer of periodic payment plan certificates

               [X]  Issuer of periodic payment plan certificates


This  filing is made  pursuant  to Rule 6c-3 and  6e-3(T)  under the  Investment
Company Act of 1940.


I.   ORGANIZATION AND GENERAL INFORMATION

     1.   (a)  FURNISH  NAME OF THE  TRUST  AND  THE  INTERNAL  REVENUE  SERVICE
               EMPLOYER IDENTIFICATION NUMBER.

               ReliaStar  Bankers Security Variable Life Separate Account I (the
               "Variable  Account").   The  Variable  Account  has  no  employer
               identification number.

          (b)  FURNISH TITLE OF EACH CLASS OR SERIES OF SECURITIES ISSUED BY THE
               TRUST.

               Flexible   premium   variable   life   insurance   policies  (the
               "Policies").

     2.   FURNISH  NAME  AND  PRINCIPAL  BUSINESS  ADDRESS  AND ZIP CODE AND THE
          INTERNAL  REVENUE  SERVICE  EMPLOYER  IDENTIFICATION  NUMBER  OF  EACH
          DEPOSITOR OF THE TRUST.

          ReliaStar  Bankers  Security  Life  Insurance  Company  ("RBSL")  1000
          Woodbury Road Woodbury, New York 11797

          Internal Revenue Service Employer 
            Identification No. 53-0242530

     3.   FURNISH  NAME  AND  PRINCIPAL  BUSINESS  ADDRESS  AND ZIP CODE AND THE
          INTERNAL  REVENUE  SERVICE  EMPLOYER  IDENTIFICATION  NUMBER  OF  EACH
          CUSTODIAN OR TRUSTEE OF THE TRUST INDICATING FOR WHICH CLASS OR SERIES
          OF SECURITIES EACH CUSTODIAN OR TRUSTEE IS ACTING.

          RBSL will be the custodian of the trust.  See the answer to Item 2 for
          the  principal  business  address,  Zip Code and the Internal  Revenue
          Service Employer Identification Number of RBSL.

     4.   FURNISH  NAME  AND  PRINCIPAL  BUSINESS  ADDRESS  AND ZIP CODE AND THE
          INTERNAL  REVENUE  SERVICE  EMPLOYER  IDENTIFICATION  NUMBER  OF  EACH
          PRINCIPAL UNDERWRITER CURRENTLY DISTRIBUTING SECURITIES OF THE TRUST.

          Sale  of  the  Policies  has  not  yet  commenced.  Washington  Square
          Securities, Inc. (the "Distributor") will act as principal underwriter
          of the  Policies  for  the  Variable  Account  at such  time as  their
          distribution commences.  The Distributor's principal business address,
          Zip Code and Internal Revenue Service Employer  Identification  Number
          are:

               20 Washington Avenue South
               Minneapolis, Minnesota 55440

               Internal Revenue Service Employer
                 Identification No. 41-0945505

     5.   FURNISH  NAME OF  STATE OR OTHER  SOVEREIGN  POWER,  THE LAWS OF WHICH
          GOVERN WITH RESPECT TO THE ORGANIZATION OF THE TRUST.

          New York

     6.   (a)  FURNISH THE DATES OF EXECUTION AND  TERMINATION  OF ANY INDENTURE
               OR  AGREEMENT  CURRENTLY  IN EFFECT  UNDER THE TERMS OF WHICH THE
               TRUST WAS ORGANIZED AND ISSUED OR PROPOSES TO ISSUE SECURITIES.

               There is no such indenture or agreement. The Variable Account was
               organized  on March  23,  1982 and the  Policies  will be  issued
               pursuant to resolutions adopted by the Board of Directors of RBSL
               on October 28, 1996,  which  resolutions  will continue in effect
               until terminated by the Board of Directors of RBSL.

          (b)  FURNISH THE DATES OF EXECUTION AND  TERMINATION  OF ANY INDENTURE
               OR AGREEMENT  CURRENTLY IN EFFECT  PURSUANT TO WHICH THE PROCEEDS
               OF PAYMENTS ON SECURITIES ISSUED OR TO BE ISSUED BY THE TRUST ARE
               HELD BY THE CUSTODIAN OR TRUSTEE.

               There is no such indenture or agreement.

     7.   FURNISH IN CHRONOLOGICAL ORDER THE FOLLOWING  INFORMATION WITH RESPECT
          TO EACH CHANGE OF NAME OF THE TRUST SINCE JANUARY 1, 1930. IF THE NAME
          HAS NEVER BEEN CHANGED, SO STATE.

          On August 1, 1996,  the name of the Variable  Account was changed from
          Bankers Security Variable Life Separate Account I to ReliaStar Bankers
          Security Variable Life Separate Account I.

     8.   STATE THE DATE ON WHICH THE FISCAL YEAR OF THE TRUST ENDS.

          December 31

          MATERIAL LITIGATION

     9.   FURNISH A DESCRIPTION OF ANY PENDING LEGAL PROCEEDINGS,  MATERIAL WITH
          RESPECT TO THE  SECURITY  HOLDERS OF THE TRUST BY REASON OF THE NATURE
          OF THE CLAIM OR THE AMOUNT THEREOF, TO WHICH THE TRUST, THE DEPOSITOR,
          OR THE PRINCIPAL  UNDERWRITER IS A PARTY OR OF WHICH THE ASSETS OF THE
          TRUST ARE THE SUBJECT,  INCLUDING THE SUBSTANCE OF THE CLAIMS INVOLVED
          IN SUCH PROCEEDING AND THE TITLE OF THE PROCEEDING.  FURNISH A SIMILAR
          STATEMENT  WITH  RESPECT  TO  ANY  PENDING  ADMINISTRATIVE  PROCEEDING
          COMMENCED BY A GOVERNMENTAL  AUTHORITY OR ANY SUCH PROCEEDING OR LEGAL
          PROCEEDING  KNOWN  TO BE  CONTEMPLATED  BY A  GOVERNMENTAL  AUTHORITY.
          INCLUDE  ANY  PROCEEDING  WHICH,   ALTHOUGH   IMMATERIAL   ITSELF,  IS
          REPRESENTATIVE  OF,  OR ONE OF,  A GROUP  WHICH  IN THE  AGGREGATE  IS
          MATERIAL.

          No legal or  administrative  proceedings  material with respect to the
          security  holders of the  Variable  Account  are  pending to which the
          Variable  Account,  RBSL or the Distributor is a party or of which the
          assets of the Variable Account are the subject.

II.  GENERAL DESCRIPTION OF THE TRUST AND SECURITIES OF THE TRUST

          GENERAL  INFORMATION  CONCERNING  THE  SECURITIES OF THE TRUST AND THE
          RIGHTS OF HOLDERS.

     10.  FURNISH A BRIEF  STATEMENT  WITH RESPECT TO THE FOLLOWING  MATTERS FOR
          EACH CLASS OR SERIES OF SECURITIES ISSUED BY THE TRUST.

          (a)  WHETHER THE SECURITIES ARE OF THE REGISTERED OR BEARER TYPE.

               Registered type

          (b)  WHETHER THE  SECURITIES  ARE OF THE  CUMULATIVE  OR  DISTRIBUTIVE
               TYPE.

               Cumulative

          (c)  THE RIGHTS OF SECURITY  HOLDERS  WITH  RESPECT TO  WITHDRAWAL  OR
               REDEMPTION.

               In  hereinafter  describing  the Policies  herein,  the following
               terms shall have the following meanings:

               Accumulation  Unit--A  unit  of  measure  used to  determine  the
               Variable Accumulation Value (see the answer to Item 10(i)).

               Accumulation  Value--The  Accumulation  Value is the total of the
               Fixed Accumulation Value and the Variable Accumulation Value (see
               the answer to Item 10(i)).

               Cash Surrender Value--The amount payable to the policy owner when
               such owner surrenders the Policy.  It is the  Accumulation  Value
               minus any  Surrender  Charge,  Loan  Amount,  and unpaid  Monthly
               Deduction.

               Death  Benefit--Shall have the meaning set forth in the answer to
               Item 10(i).

               Death Benefit  Guarantee--Shall have the meaning set forth in the
               answer to Item 10(i).

               Death  Benefit  Options--Shall  have the meaning set forth in the
               answer to Item 10(i).

               Face  Amount--The  minimum Death Benefit payable under the Policy
               as long as the Policy remains in force.

               Fixed  Account--The  Fixed Account consists of all assets of RBSL
               other than those in its separate accounts.

               Fixed Accumulation Value--Shall have the meaning set forth in the
               answer to Item 10(i).

               Funds--The  mutual funds available for investment by the Variable
               Account.

               Level  Amount  Option--Shall  have the  meaning  set forth in the
               answer to Item 10(i).

               Loan Amount--The sum of all unpaid Policy loans and unpaid Policy
               loan interest.

               Minimum Face Amount--The  minimum Face Amount shown in the Policy
               (currently $25,000).

               Minimum Monthly  Premium--Shall have the meaning set forth in the
               answer to Item 10(i).

               Monthly  Administrative  Charge--Shall have the meaning set forth
               in the answer to Item 13(d).

               Monthly  Anniversary--The  same date in each succeeding  month as
               the Policy Date. For purposes of the Variable  Account,  whenever
               the  Monthly  Anniversary  falls on a date other than a Valuation
               Date, the Monthly  Anniversary  will be considered to be the next
               Valuation Date.

               Monthly Deduction--Shall have the meaning set forth in the answer
               to Item 13(d).

               Monthly Mortality and Expense Risk Charge--Shall have the meaning
               set forth in the answer to Item 13(d).

               Net  Investment  Factor--Shall  have the meaning set forth in the
               answer to Item 10(i).

               Net  Premium--Shall  have the  meaning set forth in the answer to
               Item 13(a).

               Planned  Periodic  Premiums--Shall  have the meaning set forth in
               the answer to Item 10(i).

               Policy  Anniversary--The same date in each succeeding year as the
               Policy Date. For purposes of the Variable  Account,  whenever the
               Policy  Anniversary  falls on a date other than a Valuation Date,
               the  Policy  Anniversary  will  be  considered  to  be  the  next
               Valuation Date.

               Policy   Date--The  date  a  Policy  goes  into  effect.   Policy
               Anniversaries,   Policy   Months,   Policy   Years  and   Monthly
               Anniversaries are measured from the Policy Date.

               Policy Month--A month beginning on the Monthly Anniversary.

               Policy Year--A year beginning on the Policy Anniversary.

               Premium Expense  Charge--Shall  have the meaning set forth in the
               answer to Item 13(a).

               Premium Related Expense Charge  Reduction--Shall have the meaning
               set forth in the answer to Item 13(a).

               Rate Class--A  group of insureds RBSL  determines  based upon the
               expectation that they will have similar mortality experience.

               SEC--Securities and Exchange Commission.

               Settlement  Options--Shall  have  the  meaning  set  forth in the
               answer to Item 10(i).

               Sub-Account--A   subdivision  of  the  Variable   Account.   Each
               Sub-Account  invests  exclusively  in the  shares of a  specified
               Fund.

               Surrender  Charge--Shall have the meaning set forth in the answer
               to Item 13(a).

               Surrender Whole Life Premium--Shall have the meaning set forth in
               the answer to Item 13(a).

               Unit  Value--Shall  have the  meaning  set forth in the answer to
               Item 10(i).

               Valuation  Date--The  close of the stock market each day that the
               New York Stock Exchange is open for trading and  valuations  have
               not been suspended by the SEC.

               Valuation Period--The period of time between a Valuation Date and
               the next Valuation Date.

               Variable Accumulation  Value--Shall have the meaning set forth in
               the answer to Item 10(i).

               Variable Amount  Option--Shall  have the meaning set forth in the
               answer to Item 10(i).

               RIGHT TO RETURN POLICY AT INITIAL  ISSUE.  The Policy owner has a
               right to return the Policy for  cancellation  and a refund of all
               premiums  paid.  The owner must  return the Policy to RBSL or the
               owner's  agent and ask RBSL to cancel  the  Policy no later  than
               midnight of the 20th day after receiving it.

               RIGHT TO RETURN  POLICY  FOLLOWING A  REQUESTED  INCREASE IN FACE
               AMOUNT.  The Policy  owner has a right to cancel an  increase  in
               Face Amount and  receive a refund.  The owner must notify RBSL or
               the  owner's  agent and ask RBSL to cancel the  increase no later
               than  midnight of the 20th day after  receiving a new Policy Data
               Page.

               RBSL will  refund to the  owner an  amount  equal to all  Monthly
               Deductions attributable to the increase in Face Amount, including
               rider costs arising from the increase.

               TOTAL  SURRENDER.  A Policy owner may surrender the Policy at any
               time for its Cash  Surrender  Value by making a written  request.
               The Cash Surrender Value is the Accumulation Value of the Policy,
               reduced by any Surrender  Charge,  Loan Amount and unpaid Monthly
               Deductions.

               PARTIAL WITHDRAWAL. After the first Policy Year, policy owner may
               also  withdraw  part of the  Policy's  Cash  Surrender  Value  by
               sending RBSL a written  request.  Only one partial  withdrawal is
               allowed in any Policy year. The amount of any partial  withdrawal
               must be at least $500 and, during the first 15 Policy Years,  may
               not be more than 20% of the Cash Surrender Value on the date RBSL
               receives the owner's written request.  RBSL currently charges $10
               for  partial  withdrawals  and  guarantees  that this charge will
               never exceed $25.

               RBSL makes  partial  withdrawals  from the Fixed  Account and the
               Sub-Accounts  of the Variable  Account on a  proportionate  basis
               based upon the  Accumulation  Value.  For purposes of determining
               the  proportions,  the outstanding Loan Amount is subtracted from
               the Fixed Accumulation Value.

               EFFECT OF PARTIAL  WITHDRAWALS.  The  Accumulation  Value will be
               reduced  by the  amount  of any  partial  withdrawal.  The  Death
               Benefit  will be reduced by the amount of any partial  withdrawal
               regardless of the Death Benefit Option in effect.

               The Face  Amount  will be reduced  by the  amount of the  partial
               withdrawal if the Level Amount Option is in effect. RBSL does not
               allow a withdrawal if the Face Amount after a partial  withdrawal
               would be less than the Minimum Face Amount.

               If the Variable Amount Option is in effect, a partial  withdrawal
               does not affect the Face Amount.

               A partial  withdrawal may also cause the termination of the Death
               Benefit  Guarantee.  The  amount  of the  partial  withdrawal  is
               deducted  from the total  premiums  paid in  calculating  whether
               sufficient premiums have been paid in order to maintain the Death
               Benefit Guarantee.

          (d)  THE  RIGHTS OF  SECURITY  HOLDERS  WITH  RESPECT  TO  CONVERSION,
               TRANSFER, PARTIAL REDEMPTION AND SIMILAR MATTERS.

               CONVERSION  RIGHTS.  During  the first two  Policy  Years and the
               first two years  following a requested  increase in Face  Amount,
               the Owner has the option to convert  the Policy or any  requested
               increase in Face  Amount,  with no proof of  insurability,  for a
               life insurance policy,  the value of which will not vary with the
               investment   performance   of  the  Funds.   RBSL  does  this  by
               transferring  without charge the Variable  Accumulation Value, as
               of the date  RBSL  receives  the  owner's  request,  to the Fixed
               Account  and  issuing  a rider  to the  Policy.  The  rider  will
               prohibit the transfer of Accumulation  Value back to the Variable
               Account,  and future  premium  payments will be allocated only to
               the Fixed Account. No transfer charge is made.

               POLICY  LOANS.  A  Policy  owner  may  obtain  Policy  loans,  as
               described in the answer to Item 21.

               SURRENDERS  AND  PARTIAL  WITHDRAWALS.  A Policy  owner  may make
               surrenders and partial withdrawals, as described in the answer to
               Item 10(c).

               ALLOCATION  OF PREMIUMS.  A Policy  owner may  allocate  premiums
               among the  Sub-Accounts  of the  Variable  Account  and the Fixed
               Account, as described in the answer to Item 10(i).

               TELEPHONE TRANSFER REQUESTS.  The Owner may request a transfer by
               telephone  on any  Valuation  Date  after  a  telephone  transfer
               authorization form is completed.

               DOLLAR COST AVERAGING SERVICE. The Owner may request this service
               if the Face  Amount  is at least  $100,000  and the  Accumulation
               Value, less any Loan Amount, is at least $5,000. In this service,
               the Owner  directs  automatic  specific  periodic  transfers of a
               fixed dollar amount from any of the  Sub-Accounts  to one or more
               of the Sub-Accounts or to the Fixed Account. No transfer from the
               Fixed Account are permitted under this service. Transfers of this
               type may be made on a monthly, quarterly,  semi-annual, or annual
               basis.

               PORTFOLIO REBALANCING SERVICE. The Owner may request this service
               if the Face  Amount  is at least  $200,000  and the  Accumulation
               Value,  less any Loan Amount,  is at least $10,000.  If the Owner
               requests this service, he directs automatic periodic transfers to
               maintain specified percentage alloocations of Accumulation Value,
               less any Loan  Amount,  among the  Sub-Accounts  of the  Variable
               Account  and the Fixed  Account;  the  allocation  of future  Net
               Premium  payments  will  also  be  changed  to be  equal  to this
               specified  percentage  allocation.   Transfers  made  under  this
               service may be made on a quarterly, semi-annual, or annual basis.

               TRANSFERS.  A  Policy  owner  may  transfer  all or  part  of the
               Variable  Accumulation  Value between the  Sub-Accounts or to the
               Fixed  Account by written  request.  The owner may also  transfer
               from the Fixed Accumulation Value to the Variable Account subject
               to the restrictions listed below.

               TRANSFER  LIMITS AND CHARGES.  RBSL allows twelve  transfers in a
               Policy year but reserves the right to limit to four  transfers in
               a  Policy  Year.  Transfers  due  to  Dollar  Cost  Averaging  or
               Portfolio  Rebalancing  do not count towards  these limits.  RBSL
               currently makes no charge for each transfer and while it may make
               a charge in the future, RBSL guarantees that it will never exceed
               $25.00.  In no event,  however,  will any  charge be  imposed  in
               connection  with the exercise of a conversion  right or transfers
               occurring as a result of Policy  loans.  All  transfers  are also
               subject to any charges and conditions  imposed by the Funds whose
               shares are involved.

               To transfer all or part of the Variable Accumulation Value from a
               Sub-Account,   Accumulation  Units  are  redeemed,  on  the  next
               Valuation Date after receipt of the owner's written request,  and
               their value is  reinvested  in other  Sub-Accounts,  or the Fixed
               Account, as directed in the request.

               A Policy owner may transfer all or part of the Fixed Accumulation
               Value to the Sub-Accounts of the Variable Account, subject to the
               following transfer limitations:

                    - The request to transfer must be postmarked no more than 30
                      days before the Policy Anniversary and no later than 30 
                      days after the Policy Anniversary. Only one transfer is 
                      allowed during this period.

                    - The Fixed Accumulation Value after the transfer must be at
                      least equal to the Loan Amount.

                    - No more than 50% of the Fixed  Accumulation  Value  (minus
                      any Loan  Amount)  may be  transferred  unless the  
                      balance, after the transfer,  would  be less than  $1,000.
                      If the balance  would be  less  than  $1,000,   the  full
                      Fixed Accumulation Value (minus  any  Loan   Amount) may  
                      be transferred.

                    - The owner must transfer at least:
                         - $500, or
                         - the total Fixed  Accumulation  Value (minus any
                           Loan Amount) if less than $500.

          (e)  IF THE TRUST IS THE ISSUER OF PERIODIC PAYMENT PLAN CERTIFICATES,
               THE  SUBSTANCE OF THE  PROVISIONS  OF ANY  INDENTURE OR AGREEMENT
               WITH RESPECT TO LAPSES OR DEFAULTS BY SECURITY  HOLDERS IN MAKING
               PRINCIPAL PAYMENTS, AND WITH RESPECT TO REINSTATEMENT.

               There is no such indenture or agreement.

               LAPSE.  The  failure to make a periodic  payment  will not itself
               cause a Policy to lapse. If the Death Benefit Guarantee is not in
               effect, the Policy will lapse if, as of any Monthly  Anniversary,
               the Cash Surrender Value is less than the Monthly  Deduction due,
               and a  grace  period  of 61 days  expires  without  a  sufficient
               payment. A sufficient premium payment is any premium payment such
               that the Net  Premium is larger  than the sum of 1 + 2 where 1 is
               the  amount  by which  the  Accumulation  Value is less  than the
               Surrender Charge as of the beginning of the grace period and 2 is
               the sum of past due  Monthly  Deductions.  RBSL will  notify  the
               Policy  owner in  writing  and will  indicate  the  amount of the
               payment  required to avoid lapse. The Policy owner will then have
               a grace period of 61 days,  measured  from the date the notice is
               sent, to make sufficient  payment.  If sufficient  payment is not
               received  during the grace  period,  RBSL will lapse the  Policy.
               RBSL will use the Cash Surrender  Value to continue the Policy in
               force during the grace period.  If the Death Benefit Guarantee is
               in effect, RBSL will not lapse the Policy.

               REINSTATEMENT.  Reinstatement  means putting a lapsed Policy back
               in force.  The  Policy  owner may  reinstate  a lapsed  Policy by
               written request any time within five years after it has lapsed if
               it has not been surrendered for its Cash Surrender Value.

               To  reinstate  the Policy  and any  riders the owner must  submit
               evidence  of  insurability  satisfactory  to RBSL  and must pay a
               premium  large enough that the Net Premium is as large as the sum
               of the  Surrender  Charge after  reinstatement,  plus the Monthly
               Deductions  for the  date  of  reinstatement  and  the  following
               Monthly Anniversary.

               The Death Benefit Guarantee cannot be reinstated.

          (f)  THE  SUBSTANCE OF THE  PROVISIONS  OF ANY  INDENTURE OR AGREEMENT
               WITH  RESPECT TO VOTING  RIGHTS,  TOGETHER  WITH THE NAMES OF ANY
               PERSONS OTHER THAN  SECURITY  HOLDERS GIVEN THE RIGHT TO EXERCISE
               VOTING  RIGHTS  PERTAINING  TO  THE  TRUST'S  SECURITIES  OR  THE
               UNDERLYING SECURITIES AND THE RELATIONSHIP OF SUCH PERSONS TO THE
               TRUST.

               There is no such indenture or agreement.

               VOTING  RIGHTS.  The Policy owner has the right to instruct  RBSL
               how to vote the Fund shares attributable to the Policy at regular
               meetings  and special  meetings of the Funds.  RBSL will vote the
               Fund shares held in  Sub-Accounts  according to the  instructions
               received, as long as:

                    - The Variable  Account is registered  as a unit  investment
                      trust under the Investment Company Act of 1940, and

                    - The assets of the  Variable  Account are  invested in Fund
                      shares.

               If RBSL determines that, because of applicable law or regulation,
               it does not have to vote  according  to the  voting  instructions
               received, it will vote the Fund shares at its discretion.

               All  persons  entitled  to voting  rights and the number of votes
               they may cast are  determined  as of a record  date,  selected by
               RBSL,  not more than 90 days before the meeting of the Fund.  All
               Fund proxy  materials and  appropriate  forms used to give voting
               instructions will be sent to persons having voting interest.

               If RBSL does not receive timely voting instructions, it will vote
               the Fund  shares  in  proportion  to the  instructions  which are
               received for all Policies having a voting interest in that Fund.

               Owning  the  Policy  does not give the owner the right to vote at
               meetings of RBSL's stockholders and/or policyholders.

               DISREGARD  OF VOTING  INSTRUCTIONS.  RBSL may,  when  required by
               state  insurance   regulatory   authorities,   disregard   voting
               instructions if the instructions require that the shares be voted
               so as to cause a change in the  subclassification  or  investment
               objective of any Fund or to approve or  disapprove  an investment
               advisory  contract for any Fund. In addition,  RBSL may disregard
               voting  instructions  in favor of changes  initiated  by a Policy
               owner in the investment  policy or the investment  adviser of any
               Fund if it reasonably disapproves of such changes. A change would
               be disapproved  only if the proposed  change is contrary to state
               law or prohibited by state regulatory authorities or we determine
               that the  change  would have an  adverse  effect on the  Variable
               Account  in that the  proposed  investment  policy for a Fund may
               result in  speculative or unsound  investment.  In the event RBSL
               does disregard voting instructions,  a summary of that action and
               the  reasons  for such action will be included in the next annual
               report to owners.

          (g)  WHETHER SECURITY HOLDERS MUST BE GIVEN NOTICE OF ANY CHANGE IN:

               (1)  THE COMPOSITION OF THE ASSETS OF THE TRUST.

                    RBSL may  substitute  shares of any of the Funds for another
                    mutual fund if any of the following occurs:

                         - The  shares  of any  Fund  are  no  longer  available
                           for purchase by a Sub-Account.

                         - In  RBSL's  judgment,  investment  in a  particular
                           Fund becomes inappropriate in view of the purposes 
                           of the Policy.

                         - RBSL deems it necessary  under the Investment Company
                           Act of 1940.

                    Any substitution  would be done with notice to Policy Owners
                    and prior approval by the SEC to the extent  required by the
                    Investment Company Act of 1940 or other applicable law.

                    RBSL  also  reserves  the  right  to  establish   additional
                    Sub-Accounts  of the Variable  Account,  each of which could
                    invest in a new Fund with a specified investment  objective.
                    New  Sub-Accounts  may be  established  when,  in  the  sole
                    discretion of RBSL, marketing needs or investment conditions
                    warrant,  and any new Sub-Accounts will be made available to
                    existing  Policy owners on a basis to be determined by RBSL.
                    RBSL may also eliminate one or more  Sub-Accounts if, in its
                    sole  discretion,  marketing,  tax or investment  conditions
                    warrant.

                    In the event of any such  substitution  or change,  RBSL may
                    make  such  changes  in  Policies  as  may be  necessary  or
                    appropriate  to reflect  such  substitution  or  change.  If
                    deemed by RBSL to be in the best interests of persons having
                    voting rights under the Policies,  the Variable  Account may
                    be operated as a  management  company  under the  Investment
                    Company Act of 1940, it may be  deregistered  under that Act
                    in the event such registration is no longer required,  or it
                    may be combined with other RBSL separate accounts.

                    In no event will any of the changes  described above be made
                    without  notice to the Policy owners in accordance  with the
                    Investment Company Act of 1940.

               (2)  THE TERMS AND  CONDITIONS  OF THE  SECURITIES  ISSUED BY THE
                    TRUST.

                    Notice  must be given to Policy  owners of any change in the
                    terms and conditions of the Policies. See the answer to Item
                    10 (h)(2) with respect to the  necessity of a consent by the
                    Policy owners to such changes.

               (3)  THE PROVISIONS OF ANY INDENTURE OR AGREEMENT OF THE TRUST.

                    No  change  in  the  resolution  establishing  the  Variable
                    Account or in any agreement  relating to the manner in which
                    it is operated will be made without  notice to Policy owners
                    if such change would  adversely  affect any right or benefit
                    to which they are entitled.

               (4)  THE IDENTITY OF THE DEPOSITOR, TRUSTEE OR CUSTODIAN.

                    The Variable  Account has no trustee.  The  depositor of the
                    Variable Account cannot be changed.  Any change in custodian
                    will be reflected in the Variable Account's prospectus which
                    is distributed to each Policy owner on an annual basis.

          (h)  WHETHER THE CONSENT OF SECURITY  HOLDERS IS REQUIRED IN ORDER FOR
               ACTION TO BE TAKEN CONCERNING ANY CHANGE IN:

               (1)  THE COMPOSITION OF THE ASSETS OF THE TRUST.

                    The  consent of the Policy  owners is not  required in order
                    for RBSL to invest  the  assets of the  Variable  Account in
                    securities  other than  shares of the Funds as a  substitute
                    for such shares already purchased or as the securities to be
                    purchased  in the  future.  Such  action  will be  taken  in
                    compliance  with  applicable  law  (including  any  approval
                    required by the SEC).  The  consent of Policy  owners is not
                    required  in order for RBSL to make  available,  subject  to
                    applicable  law,  additional  Sub-Accounts  of the  Variable
                    Account investing in additional Funds.

               (2)  THE TERMS AND  CONDITIONS  OF THE  SECURITIES  ISSUED BY THE
                    TRUST.

                    The  terms and  conditions  of a Policy  cannot  be  changed
                    without the consent of a Policy owner.

               (3)  THE PROVISIONS OF ANY INDENTURE OR AGREEMENT OF THE TRUST.

                    No.

               (4)  THE IDENTITY OF THE DEPOSITOR, TRUSTEE OR CUSTODIAN.

                    The Variable  Account has no trustee.  The  depositor of the
                    Variable  Account  cannot be changed.  The consent of Policy
                    owners is not required  for action to be taken  concerning a
                    change in the identity of the custodian.

          (i)  ANY OTHER PRINCIPAL FEATURE OF THE SECURITIES ISSUED BY THE TRUST
               OR ANY OTHER PRINCIPAL RIGHT, PRIVILEGE OR OBLIGATION NOT COVERED
               BY SUBDIVISIONS (A) TO (G) OR BY ANY OTHER ITEM IN THIS FORM.

               PREMIUMS.  There is no insurance under a Policy until the initial
               premium  is paid,  which  must be equal  to or  greater  than the
               Minimum Monthly Premium.

               The Policy owner  chooses the initial  allocation of Net Premiums
               to the Fixed Account and the Sub-Accounts of the Variable Account
               on the  application  for the  Policy.  The owner may  change  the
               allocation at any time by notifying RBSL in writing. Changes will
               not be effective until the date RBSL received the owner's request
               and will only  affect  premiums  RBSL  receives  on or after that
               date.  The  allocation  may be 100% to any  Account or divided in
               whole percentage points totaling 100%. RBSL reserves the right to
               adjust any allocation to eliminate fractional percentages.

               After the initial premium, the owner may determine the amount and
               timing  of  subsequent  premium  payments  within  the  following
               restrictions:

                    - RBSL may  choose  not to  accept  any  premium  less  than
                      $25.00.

                    - While there is no stated maximum,  RBSL reserves the right
                      to limit the amount of any premium payment.

                    - RBSL  may  require  additional  evidence  of  insurability
                      satisfactory  to  it  if any  premium would  increase  the
                      difference between the Death Benefit and the Accumulation
                      Value.

                    - RBSL will return to the owner any premium paid which would
                      disqualify the policy for treatment as life insurance 
                      under federal law.

               The Policy owner may choose a Planned  Periodic  Premium schedule
               which  indicates a preference as to future  amounts and frequency
               of payment.  The Planned Periodic  Premiums may be paid annually,
               semi-annually,  quarterly or, if the owner chooses, RBSL can also
               deduct  Planned  Periodic  Premiums from the owner's bank account
               monthly.

               The amount and  frequency of initial  Planned  Periodic  Premiums
               will be shown in the  Policy.  The  Policy  owner may  change the
               Planned Periodic Premium at any time by written request. RBSL may
               limit the amount of any increase.

               The  amount  and  frequency  of  premium   payments  will  affect
               Accumulation Value, Cash Surrender Value, and how long the Policy
               will  remain  in  force.  Failure  to make any  Planned  Periodic
               Premium payment will not, however, necessarily result in lapse of
               the Policy.

               Premiums,  other than Planned Periodic  Premiums,  may be paid at
               any time  while the  Policy  is in force  other  than as  paid-up
               insurance.  RBSL  may  limit  the  number  and  amount  of  these
               additional payments.

               DEATH BENEFIT. Like traditional life insurance, RBSL pays a Death
               Benefit if the insured dies while the Policy is in force.  All or
               part  of  the  Death   Benefit   may  be  paid  in  cash  to  the
               beneficiaries  or  under  one or more of the  Settlement  Options
               offered by RBSL.

               As long as the Policy is in force, RBSL guarantees that the Death
               Benefit under either Death Benefit  Option  described  below will
               not be less than the current  Face  Amount  minus any Loan Amount
               and unpaid Monthly Deductions.

               The Policy owner may choose one of two Death  Benefit  Options on
               the application. Under the Level Amount Option, The Death Benefit
               is the Face Amount.  Under the Variable Amount Option,  the Death
               Benefit is the Face  Amount  plus the  Accumulation  Value of the
               Policy.

               Under either  option,  RBSL may be required to increase the Death
               Benefit to maintain the Policy's  qualification as life insurance
               for  federal  income tax  purposes.  For the Policy to qualify as
               life  insurance,  current  federal  law  requires  that the Death
               Benefit  be  at  least  a  certain   multiple  of  the   Policy's
               Accumulation  Value.  These  multiples  are shown on the  Minimum
               Death  Benefit  Table in the Policy and are  subject to change as
               the federal income tax laws and regulations change.

               Assuming the same premium  payments and  investment  performance,
               the Death  Benefit  will be  higher  under  the  Variable  Amount
               Option, and the Accumulation Value (and the Cash Surrender Value)
               will be lower  under  that  option  than  under the Level  Amount
               Option. Also, the Minimum Monthly Premium for the Variable Amount
               Option is greater than for the Level Amount Option.

               REQUESTED CHANGES IN FACE AMOUNT. Subject to certain limitations,
               the Policy  owner may request an increase or decrease in the Face
               Amount.  No  increase  or  decrease  in the Face  Amount  will be
               permitted during the first two Policy years.

               For an increase in the Face  Amount,  a written  request  must be
               submitted.   RBSL  may  also  require   additional   evidence  of
               insurability  satisfactory  to  it.  The  effective  date  of the
               increase  will be the Monthly  Anniversary  on or next  following
               RBSL's  approval of the  increase.  The  increase may not be less
               than $5,000 and no increase  will be  permitted  after the Policy
               Anniversary  on or next  following the insured's  75th  birthday.
               RBSL will deduct any charges  associated  with the increase  from
               the  Accumulation  Value,  whether  or  not  the  owner  pays  an
               additional premium in connection with the increase.

               Any  decrease in the Face Amount will be effective on the Monthly
               Anniversary  on or next  following  receipt  by RBSL of a written
               request.  The owner cannot  request a decrease in the Face Amount
               more  frequently  than once  every six  months.  The Face  Amount
               remaining in force after any  requested  decrease may not be less
               than the Minimum  Face Amount  shown in the Policy.  Under RBSL's
               current  policies,  the Minimum  Face  Amount is $25,000,  but is
               reserves the right to  establish a different  Minimum Face Amount
               in the  future.  If,  following a decrease  in Face  Amount,  the
               Policy would no longer  qualify as life  insurance  under federal
               tax law, the decrease may be limited,  or, at the owner's option,
               part of the  Accumulation  Value may be returned to the owner, to
               the extent necessary to meet these requirements.  For purposes of
               determining  the  cost of  insurance,  the  Face  Amount  will be
               reduced in the following order:

                    (a)  The Face Amount provided by the most recent increase;

                    (b)  The next most recent increases successively; and

                    (c)  The Face Amount when the Policy was issued.

               An  increase  or  decrease in Face Amount will affect the Monthly
               Deduction  because the cost of  insurance,  the  Monthly  Expense
               Charge,  and the Death Benefit  Guarantee  Charge depend upon the
               Face Amount.  The charge for certain optional  insurance benefits
               may  also be  affected.  An  increase  in the  Face  Amount  will
               increase the Surrender Charge,  but a decrease in the Face Amount
               will not reduce the Surrender Charge.

               An increase in the Face Amount will increase the Minimum  Monthly
               Premium  as of the  effective  date of the  increase.  Therefore,
               additional premium payments may be required to maintain the Death
               Benefit Guarantee.  A decrease in the Face Amount will reduce the
               Minimum Monthly Premium as of the effective date of the decrease.

               CHANGES IN DEATH BENEFIT OPTION.  The Policy owner may request in
               writing to change the Death Benefit Option.  If the owner changes
               from the Level Amount Option to the Variable  Amount Option,  the
               Face  Amount  is  decreased.  The new Face  Amount  is the  Death
               Benefit   minus  the   Accumulation   Value  as  of  the  Monthly
               Anniversary  on or next  following  the date  RBSL  receives  the
               request.  The owner cannot change the Death Benefit Option if the
               resulting Face Amount would fall below the Minimum Face Amount.

               If the owner changes from the Variable Amount Option to the Level
               Amount Option, the Face Amount is increased.  The new Face Amount
               is the  Accumulation  Value plus the Face  Amount on the  Monthly
               Anniversary  on or next  following  the date  RBSL  receives  the
               request.

               An increase or decrease in Face Amount resulting from a change in
               the Death  Benefit  Option  will  affect  the  Monthly  Deduction
               because the cost of insurance,  the Monthly Expense  Charge,  and
               the Death Benefit  Guarantee  Charge depend upon the Face Amount.
               The charge for certain  optional  insurance  benefits may also be
               affected. The Surrender Charge,  however, will not be affected by
               a change in the Death Benefit Option.

               A change in Death Benefit Option will affect the Minimum  Monthly
               Premium  as of  the  effective  date  of the  change.  Therefore,
               additional premium payments may be required to maintain the Death
               Benefit Guarantee.

               Changes in the Death  Benefit  Option do not  require  additional
               evidence of insurability.

               DEATH BENEFIT GUARANTEE.  Until the Policy Anniversary on or next
               following the insured's 65th birthday,  if the Policy owner meets
               the Minimum Premium  Requirement  described below RBSL guarantees
               that  it  will  not  lapse  the  Policy  even  if the  investment
               performance  of the selected  Funds  results in a Cash  Surrender
               Value that is not sufficient to pay the Monthly Deduction due.

               The  Minimum  Premium  Requirement  is met if,  on  each  Monthly
               Anniversary  on or before the Policy  Anniversary  next following
               the  insured's  65th  birthday,  A is equal to or greater than B,
               where:

               A
               is the sum of all premiums paid minus any partial withdrawals and
               any Loan Amount.

               B
               is the sum of the Minimum Monthly Premiums since the Policy Date,
               including  the Minimum  Monthly  Premium for the current  Monthly
               Anniversary.

               The amount of the Minimum  Monthly  Premium  will be set forth in
               the Policy,  and will depend on the insured's  sex, age at issue,
               Rate Class,  Death Benefit Option,  optional  insurance  benefits
               added by rider, and the initial Face Amount.

               Although  RBSL  determines  each month  whether or not the Policy
               owner has met the Minimum Premium Requirement, the owner does not
               have to pay premiums monthly.

               If on any Monthly  Anniversary the Minimum Premium Requirement is
               not met,  RBSL will send the Policy  owner notice of the required
               payment.  If RBSL does not  receive the  required  premium by the
               next  Monthly  Anniversary,  the Death  Benefit  Guarantee  is no
               longer in effect and cannot be reinstated.

               The Minimum  Monthly  Premium,  and therefore the Minimum Premium
               Requirement, will be affected by a requested increase or decrease
               in the Face Amount, a change in the Death Benefit Option,  or the
               addition or termination  of a Policy rider.  RBSL will notify the
               Policy owner of any changes in the Minimum Monthly Premium.

               ACCUMULATION VALUE. The Accumulation Value of the Policy is equal
               to the sum of the  Variable  Accumulation  Value  plus the  Fixed
               Accumulation Value. The Policy may be surrendered at any time for
               its  Accumulation  Value reduced by any Surrender  Charges,  Loan
               Amount and unpaid Monthly Deductions (that is, its Cash Surrender
               Value).

                    Variable Accumulation Value

               The  Variable  Accumulation  Value is the total of the  values in
               each Sub-Account. The value for each Sub-Account is equal to:

                    A multiplied by B, where:

               A
               is the  current  number of  Accumulation  Units  relating  to the
               Policy.

               B
               is the current Unit Value.

               The Variable  Accumulation Value will vary from Valuation Date to
               Valuation Date reflecting changes in A and B above.

                    ACCUMULATION  UNITS. When transactions are made which affect
                    the  Variable   Accumulation   Value,   dollar  amounts  are
                    converted to Accumulation  Units. The number of Accumulation
                    Units for a  transaction  is found by  dividing  the  dollar
                    amount of the transaction by the current Unit Value.

                    The number of Accumulation Units for a Sub-Account increases
                    when:

                         - Net  Premiums  are  credited  to  that  Sub-Account;
                           or 
                         - Transfers from the Fixed Account or other 
                           Sub-Accounts are credited to that Sub-Account.

                    The number of Accumulation Units for a Sub-Account decreases
                    when:

                         - The  Policy  owner  takes  out a  Policy  loan  from
                           that Sub-Account;

                         - The owner takes a partial withdrawal from  that
                           Sub-Account;

                         - RBSL takes a portion of the  Monthly  Deduction from
                           that Sub-Account; or

                         - Transfers are made from that Sub-Account to the 
                           Fixed Account or other Sub-Accounts.

                    UNIT  VALUE.  The  Unit  Value  for  a  Sub-Account  on  any
                    Valuation Date is equal to the previous Unit Value times the
                    Net Investment Factor for that Sub-Account for the Valuation
                    Period  ending on that  Valuation  Date.  The Unit  Value is
                    initially  set when the  Sub-Account  first  purchased  Fund
                    shares.

                    NET INVESTMENT FACTOR. The Net Investment Factor is a number
                    that  reflects  charges  to the  Policy  and the  investment
                    performance during a Valuation Period of the Fund in which a
                    Sub-Account  is invested.  If the Net  Investment  Factor is
                    greater  than one, the Unit Value is  increased.  If the Net
                    Investment  Factor  is less  than  one,  the  Unit  Value is
                    decreased.  The Net  Investment  Factor for a Sub-Account is
                    determined  by dividing A by B and then  subtracting  C from
                    the result,

                         (A/B) - C, where:

                    A
                    is the net result of:

                         - the net asset  value per share of the Fund shares in 
                           which the  Sub-Account invests, determined at the end
                           of the current Valuation Period;

                         - plus the per share  amount of any dividend or capital
                           gain distributions made on the Fund shares in which
                           the Sub-Account invests during the current Valuation
                           Period;

                         - plus or minus a per share  charge or credit  for any
                           taxes reserved for which RBSL determines to have 
                           resulted from the investment operations of the Sub-
                           Account and to be applicable to the Policy.

                    B
                    is the result of:

                         - the net asset  value per share of the Fund  shares
                           held in the Sub-Account, determined at the end of the
                           last prior Valuation Period;

                         - plus or minus a per share  charge or credit  for any
                           taxes reserved  for during the last prior  Valuation
                           Period which RBSL determines to have resulted from  
                           the investment operations of the Sub-Account and to 
                           be applicable to the Policy.

                    C
                    is a factor  representing  the Mortality Risk Charge and the
                    Expense Risk Charge deducted from the  Sub-Account  (see the
                    answer to Item 13(a)),  which factor is equal,  on an annual
                    basis,  to  .75%  of  the  daily  net  asset  value  of  the
                    Sub-Account.

                    Fixed Accumulation Value

                    The Fixed  Accumulation  Value on the Policy Date is the Net
                    Premium credited to the Fixed account on that date minus the
                    Monthly Deduction applicable to the Fixed Accumulation Value
                    for the first Policy Month.

                    After  the  Policy  Date,  the Fixed  Accumulation  Value is
                    calculated as:

                         A + B + C + D - E - F, where:

               A
               is  the  Fixed   Accumulation  Value  on  the  preceding  Monthly
               Anniversary,  plus interest from the Monthly  Anniversary  to the
               date of the calculation.

               B
               is the total of the Net  Premiums  credited to the Fixed  Account
               since the preceding Monthly  Anniversary,  plus interest from the
               date premiums are credited to the date of the calculation.

               C
               is the total of the  transfers  from the Variable  Account to the
               Fixed  Account  since the  preceding  Monthly  Anniversary,  plus
               interest   from  the  date  of   transfer  to  the  date  of  the
               calculation.

               D
               is the total of the Loan  Amounts  transferred  from the Variable
               Account since the preceding Monthly Anniversary.

               E
               is the total of the  transfers to the  Variable  Account from the
               Fixed  Account  since the  preceding  Monthly  Anniversary,  plus
               interest   from  the  date  of   transfer  to  the  date  of  the
               calculation.

               F
               is the total of the partial  withdrawals  from the Fixed  Account
               since the preceding Monthly  Anniversary,  plus interest from the
               date or withdrawal to the date of the calculation.

               If the date of the  calculation  is a Monthly  Anniversary,  RBSL
               also  reduces  the  Fixed  Accumulation  Value by the  applicable
               Monthly  Deduction  for the Policy  Month  following  the Monthly
               Anniversary.

               The minimum interest rate applied in the calculation of the Fixed
               Accumulation Value is an effective annual rate of 4%. Interest in
               excess of the minimum rate may be applied in the  calculation  of
               the Fixed  Accumulation  Value in a manner  which RBSL's Board of
               Directors determines.

               LOANS. See the answer to Item 21.

               SETTLEMENT OPTIONS.  Settlement Options are ways the Policy owner
               can choose to have the  Policy's  proceeds  paid.  These  options
               apply to proceeds paid:

                    - At the insured's death.
                    - On surrender of the Policy.

               The proceeds are paid to one or more payees.  The proceeds may be
               paid  in a lump  sum or may be  applied  to one of the  following
               Settlement  Options.  A  combination  of options may be used.  At
               least  $2,500  must be applied to any option for each payee under
               that option. Under an installment option, each payment must be at
               least  $25.00.  RBSL may adjust the interval to make each payment
               at least $25.00.

               Proceeds  applied to any Option no longer  earn  interest  at the
               rate  applied  to  the  Fixed  Account  or   participate  in  the
               investment performance of the Funds.

               Option  1 -  Proceeds  are  left  with  RBSL  to  earn  interest.
               Withdrawals and any changes are subject to approval by RBSL.

               Option 2 - Proceeds and  interest are paid in equal  installments
               of a specified  amount  until the  proceeds  and interest are all
               paid.

               Option 3 - Proceeds and  interest are paid in equal  installments
               for a specified  period  until the  proceeds and interest are all
               paid.

               Option  4 - The  proceeds  provide  an  annuity  payment  with  a
               specified number of months "certain".  The payments are continued
               for the life of the  primary  payee.  If the  primary  payee dies
               before the certain  period is over,  the  remaining  payments are
               paid to a contingent payee.

               Option 5 - The  proceeds  provide a life  income for two  payees.
               When one payee dies,  the  surviving  payee  receives  2/3 of the
               amount of the joint monthly payment for life.

               Option 6 - The proceeds  are used to provide an annuity  based on
               the rates in effect when the proceeds are applied.  RBSL does not
               apply this option if a similar  option would be more favorable to
               the payee at that time.

               RBSL bases the interest rate for proceeds applied under options 1
               and 2 on the interest  rate it declares on funds that we consider
               to  be  in  the  same   classification   based  on  the   option,
               restrictions on withdrawal,  and other factors. The interest rate
               will never be less than an effective annual rate of 3 1/2%.

               In  determining  amounts to be paid  under  options 3 and 4, RBSL
               assumes interest at an effective annual rate of 3 1/2%. Also, for
               option 3 and  "certain"  periods under option 4, RBSL credits any
               excess  interest it may declare on funds that it  considers to be
               in the same classification  based on the option,  restrictions on
               withdrawal, and other factors.

               PAID-UP  INSURANCE.  At any time before the Policy Anniversary on
               or next following the insured's  95th birthday,  the Policy owner
               may, by written request, use the Cash Surrender Value to purchase
               a single premium  paid-up life  insurance  under the Policy for a
               reduced  Face  Amount.  If the Policy is in force as paid-up life
               insurance,  the owner cannot pay any additional  premiums or make
               any  partial  withdrawals.  The Face  Amount  and cash  surrender
               values will be based on an effective  annual  interest rate of 4%
               and mortality  charges based on the  Commissioners  1980 Standard
               Ordinary Mortality Table.

               On the Policy Anniversary on or next following the insured's 95th
               birthday,  the Cash Surrender Value will automatically be used to
               purchase single premium  paid-up life  insurance.  In most cases,
               the Face Amount of the paid-up life  insurance  will be less than
               the Death Benefit at that time.

          INFORMATION   CONCERNING   THE   SECURITIES   UNDERLYING  THE  TRUST'S
          SECURITIES

     11.  DESCRIBE BRIEFLY THE KIND OR TYPE OF SECURITIES COMPRISING THE UNIT OF
          SPECIFIED SECURITIES IN WHICH SECURITY HOLDERS HAVE AN INTEREST.

          INVESTMENTS  OF THE VARIABLE  ACCOUNT.  There are currently  seventeen
          investment alternatives available under the Variable Account. Fidelity
          Management & Research  Company is the investment  adviser for the five
          portfolios  of VIP  and  the  four  portfolios  of VIP  II.  Northstar
          Investment  Management  Corporation,  an  affiliate  of  RBSL,  is the
          investment  adviser of the two Northstar Funds.  Putnam  Management is
          the  investment  adviser for the six funds of Putnam  Variable  Trust.
          RBSL reserves the right to establish  additional  Sub-Accounts  of the
          Variable  Account,  each of which  could  invest  in a new Fund with a
          specified  investment  objective.  New Sub-Accounts may be established
          when,  in  RBSL's  sole  discretion,  marketing  needs  or  investment
          conditions warrant, and any new Sub-Accounts will be made available to
          existing Policy owners on a basis determined by RBSL.

          The  Net  Premium  is  credited  to one or  more  Sub-Accounts  of the
          Variable  Account  chosen by you. The assets of each  Sub-Account  are
          invested in shares, at net asset value, of the related Fund.

          A Sub-Account may be unable to invest Net Premiums in shares of a Fund
          if Net  Premiums  to be invested in shares in that Fund on a given day
          do not meet the Fund's  minimum  purchase  requirement,  or if, in the
          judgment  of RBSL's  management,  further  investment  in that  Fund's
          shares would be  inappropriate  in view of the purposes of the Policy.
          If RBSL is unable to invest Net Premiums for one of the above reasons,
          it will  notify the  owners of the  Policies  involved.  They may then
          request the  allocation of the premiums to a different  Sub-Account or
          to the Fixed Account. The new allocation will be effective on the next
          Valuation Date after RBSL receives an owner's written  request.  Until
          RBSL receives such a written request, the Net Premium will be invested
          in shares of VIP's Money Market Portfolio, if available;  otherwise it
          will be credited to the Fixed Account.

          The Funds  currently  offered are described  below. A brief summary of
          investment objectives is contained in the description of each Fund.

          The Funds  described  below  distribute  dividends and capital  gains.
          However, distributions are automatically reinvested in additional Fund
          shares, at net asset value. The Sub-Account received the distributions
          which are then  reflected in the Unit Value of that  Sub-Account  (see
          the answer to Item 10(I)).

          FIDELITY'S VARIABLE INSURANCE PRODUCTS FUND (VIP)

          VIP is a  mutual  fund  trust  currently  includinig  five  investment
          portfolios, each with a different investment objective.

          MONEY  MARKET  PORTFOLIO  seeks to obtain  as high a level of  current
          income  as  is  consistent  with  preserving   capital  and  providing
          liquidity.  The portfolio will invest only in high-quality U.S. dollar
          denominated money market  instruments of domestic and foreign issuers.
          An  investment  in the  portfolio is not insured or  guaranteed by the
          U.S. Government, and there can be no assurance that the Portfolio will
          maintain a stable net asset value per share of $1.00.

          HIGH INCOME  PORTFOLIO  seeks to obtain a high level of current income
          by investing  primarily  in  high-yielding,  lower-rated  fixed-income
          securities  (sometimes  referred  to  as  "junk  bonds"),  while  also
          considering growth of capital. Lower-rated fixed-income securities are
          considered  speculative  and  involve  greater  risk of  default  than
          higher-rated  fixed-income  securities  and are more  sensitive to the
          issuer's  capacity  to pay.  Consult  the VIP  Prospectus  for further
          information on the risks associated with the portfolio's investment in
          lower-rated fixed-income securities.

          EQUITY-INCOME PORTFOLIO seeks reasonable income by investing primarily
          in  income-producing  equity securities.  In choosing these securities
          the   portfolio   will  also   consider  the   potential  for  capital
          appreciation. The portfolio's goal is to achieve a yield which exceeds
          the composite yield on the securities comprising the Standard & Poor's
          Composite Index of 500 Stocks.

          GROWTH PORTFOLIO seeks to achieve capital appreciation.  The portfolio
          normally  purchases  common stocks,  although its  investments are not
          restricted to any one type of security.  Capital appreciation may also
          be found in other types of securities,  including  bonds and preferred
          stocks.

          OVERSEAS PORTFOLIO seeks long term growth of capital primarily through
          investments in foreign  securities.  The Overseas Portfolio provides a
          means for investors to diversify their own portfolios by participating
          in companies and economies outside of the United States.

          FIDELITY'S VARIABLE INSURANCE PRODUCTS FUND II (VIP II)

          VIP II is a mutual  fund trust  currently  including  five  investment
          portfolios, each with a different investment objective. Presently, the
          following four portfolios are available within this Policy.

          ASSET MANAGER PORTFOLIO seeks high total return with reduced risk over
          the  long-term by  allocating  its assets  among  domestic and foreign
          stocks, bonds and short-term fixed-income instruments.

          INVESTMENT  GRADE  BOND  PORTFOLIO  seeks as high a level  of  current
          income as is consistent with the  preservation of capital by investing
          in a broad range of investment-grade fixed-income securities.

          INDEX  500  PORTFOLIO  seeks  to  provide   investment   results  that
          correspond  to the total  return  (i.e.,  the  combination  of capital
          changes and  income) of common  stocks  publicly  traded in the United
          States. In seeking this objective, the portfolio attempts to duplicate
          the  composition  and total return of the Standard & Poor's  Composite
          Index of 500 Stocks while keeping transaction costs and other expenses
          low. The portfolio is designed as a long-term investment option.

          CONTRAFUND  PORTFOLIO  seeks  capital  appreciation  by  investing  in
          companies  believed  to be  undervalued  due to an overly  pessimistic
          appraisal by the public.  The  portfolio  invests  primarily in common
          stock and  securities  convertible  into common stock,  but it has the
          flexibility to invest in any type of security that may produce capital
          appreciation.

          NORTHSTAR VARIABLE TRUST (NORTHSTAR)

          Northstar is a diversified  management  investment  company  currently
          offering  four  investment  funds,  each with a  different  investment
          objective.  The following two Northstar Funds are available under this
          Policy.

          NORTHSTAR  INCOME AND GROWTH FUND is a diversified  portfolio  with an
          investment  objective  of seeking  current  income  balanced  with the
          objective of achieving  capital  appreciation.  This Fund will seek to
          achieve its  objective  through  investments  in common and  preferred
          stocks,  convertible  securities,   investment  grade  corporate  debt
          securities and government securities,  selected for their prospects of
          producing  income and  capital  appreciation.  Wilson/Bennett  Capital
          Management,  Inc.  ("Wilson/Bennett")  is the sub-adviser to this Fund
          and is  responsible  for the day-to-day  investment  management of the
          Fund,  subject to the  supervision of the  investment  adviser and the
          Trustees of the Fund.

          NORTHSTAR  MULTI-SECTOR  BOND FUND is a diversified  portfolio with an
          investment objective of maximizing current income. This Fund will seek
          to achieve its objective by investment in the following sectors of the
          fixed income securities  markets:  (a) securities issued or guaranteed
          as to principal  and interest by the U.S.  Government,  its  agencies,
          authorities or instrumentalities;  (b) investment grade corporate debt
          securities; (c) investment grade or comparable quality debt securities
          issued by foreign corporate issuers,  and securities issued by foreign
          governments and their political subdivisions, limited to 35% of assets
          determined at the time of  investment;  and (d) high  yield-high  risk
          fixed income securities of U.S. and foreign issuers, limited to 50% of
          assets determined at the time of investment.

          PUTNAM VARIABLE TRUST

          Putnam  Variable  Trust is a mutual fund  currently  offering  sixteen
          investment  funds,  each  with  a  different   investment   objective.
          Presently,  only the  following  six funds are  available  under  this
          Policy.

          PUTNAM VT DIVERSIFIED INCOME FUND seeks high current income consistent
          with capital  preservation by investing in the following three sectors
          of the fixed income securities  markets:  a U.S.  Government Sector, a
          High Yield Sector  (which  invests  primarily in  securities  that are
          commonly known as "junk bonds") and an International  Sector.  Consult
          the Putnam  Variable Trust  Prospectus for further  information on the
          risks   associated   with  this  Fund's   investments   in  high-yield
          higher-risk fixed income securities.

          PUTNAM VT GROWTH AND  INCOME  FUND seeks  capital  growth and  current
          income by investing  primarily in common  stocks that offer  potential
          for capital growth, current income, or both.

          PUTNAM VT UTILITIES  GROWTH AND INCOME FUND seeks  capital  growth and
          current  income by  concentrating  its  investments in debt and equity
          securities issued by companies in the public utilities industries.

          PUTNAM VT VOYAGER FUND seeks  capital  appreciation  primarily  from a
          portfolio  of common  stocks  that  Putnam  Management  believes  have
          potential for capital appreciation that is significantly  greater than
          that of market averages.

          PUTNAM VT ASIA  PACIFIC  GROWTH  FUND seeks  capital  appreciation  by
          investing  primarily in securities of companies located in Asia and in
          the Pacific Basin. The Fund's investments will normally include common
          stocks, preferred stocks, securities convertible into common stocks or
          preferred stocks,  and warrants to purchase common stocks or preferred
          stocks.

          PUTNAM VT NEW OPPORTUNITIES FUND seeks long-term capital  appreciation
          by investing  principally  in common stocks of companies in sectors of
          the economy which Putnam  Management  believes  possess  above-average
          long-term growth potential.


     12.  IF THE TRUST IS THE ISSUER OF PERIODIC  PAYMENT PLAN  CERTIFICATES AND
          IF  ANY  UNDERLYING  SECURITIES  WERE  ISSUED  BY  ANOTHER  INVESTMENT
          COMPANY, FURNISH THE FOLLOWING INFORMATION FOR EACH SUCH COMPANY.

          (a)  NAME OF COMPANY.

               See the answer to Item 11.

          (b)  NAME AND PRINCIPAL BUSINESS ADDRESS OF DEPOSITOR.

               Not applicable.

          (c)  NAME AND PRINCIPAL ADDRESS OF TRUSTEE OR CUSTODIAN.

               See the answer to Item 11.

          (d)  NAME AND PRINCIPAL ADDRESS OF PRINCIPAL UNDERWRITER.

               Not applicable.

          (e)  THE PERIOD DURING WHICH THE  SECURITIES OF SUCH COMPANY HAVE BEEN
               THE UNDERLYING SECURITIES.

               Not applicable.

          INFORMATION CONCERNING LOADS, FEES, CHARGES AND EXPENSES

     13.  (a)  FURNISH THE FOLLOWING INFORMATION WITH RESPECT TO EACH LOAD, FEE,
               EXPENSE OR CHARGE TO WHICH (1)PRINCIPAL  PAYMENTS, (2) UNDERLYING
               SECURITIES, (3) DISTRIBUTIONS, (4) CUMULATED  OR REINVESTED
               DISTRIBUTIONS OR INCOME,  AND (5) REDEEMED OR LIQUIDATED ASSETS 
               OF THE TRUST'S SECURITIES ARE SUBJECT.

               (A)  THE NATURE OF SUCH LOAD, FEE, EXPENSE OR CHARGE;

               (B)  THE AMOUNT THEREOF;

               (C)  THE NAME OF THE PERSON TO WHOM SUCH AMOUNTS ARE PAID AND HIS
                    RELATIONSHIP TO THE TRUST;

               (D)  THE  NATURE  OF THE  SERVICES  PERFORMED  BY SUCH  PERSON IN
                    CONSIDERATION FOR SUCH LOAD, FEE, EXPENSE OR CHARGE.

                    (1)  PRINCIPAL PAYMENTS

               RBSL deducts a Premium Expense Charge which is 5% of each premium
               payment. The amount remaining after RBSL has deducted the Premium
               Expense Charge is called the Net Premium. The Net Premium is then
               credited  to  the  Fixed  Account  and  the  Sub-Accounts  of the
               Variable Account according to the owner's allocation.

                    (2)  UNDERLYING SECURITIES

               The investment adviser of each of the currently  available Funds,
               is  paid  a  daily  charge  by  such  Funds  for  its  investment
               management services.

                    (3)  DISTRIBUTIONS

               SURRENDER  CHARGE.  During  the first  fifteen  Policy  Years and
               during the first fifteen years  following any requested  increase
               in Face Amount, RBSL makes a Surrender Charge if the Policy owner
               surrenders the Policy or the Policy lapses. The maximum Surrender
               Charge for the Initial Face Amount or any  requested  increase in
               Face  Amount  will be  determined  on the  Policy  Date or on the
               effective  date  of  any  requested  increase  respectively.  The
               Surrender  Charge  remains  level for the first five years in the
               relevant  15 year  period,  and then  reduces  in  equal  monthly
               increments until it becomes zero at the end of 15 years.  Thus if
               the Policy  remains in force during the entire  relevant  15-year
               period,  the Policy Owner does not pay the Surrender Charge.  The
               Surrender  Charge will vary  depending on the Age of the Insured,
               the sex of the Insured, and the Rate Class of the Insured (on the
               Policy  Date  or on the  effective  date of an  increase  in Face
               Amount).

               The Surrender Charge for the Initial Face Amount or any requested
               increase  in Face Amount is  determined  by  multiplying  (i) the
               applicable  Surrender  Charge Per  $1,000  Face  Amount  from the
               Maximum Surrender Charge Per $1,000 of Fair Amount Table which is
               part of the Policy ("Appendix D") by (ii) the Initial Face Amount
               or the Face Amount of the increase,  as applicable,  and by (iii)
               the applicable  percentage from the Surrender  Charge  Percentage
               Table  below,  and then  dividing  this amount by 1000.  Then the
               Surrender  Charge is reduced  by the  Premium  Related  Surrender
               Charge Reduction.

               The Premium Related Surrender Charge Reduction will apply only to
               the  Surrender  Charge  for the  Initial  Face  Amount  when  the
               cumulative premiums are less than the Surrender Charge Whole Life
               Premium.  The Premium Related  Surrender Charge Reduction will be
               zero when the  cumulative  premiums equal or exceed the Surrender
               Charge Whole Life Premium.  The Premium Related  Surrender Charge
               Reduction  also will be zero for any  requested  increase in Face
               Amount.  The Premium Related  Surrender  Charge Reduction for the
               Initial  Face  Amount is  calculated  by  multiplying  70% by the
               excess of (i) the  Surrender  Charge Whole Life Premium over (ii)
               the cumulative premiums.  The Surrender Charge Whole Life premium
               is calculated by multiplying (i) the applicable  Surrender Charge
               Whole Life  premium per $1000 of Face Amount from a table  called
               Surrender  Charge  Whole Life  Premium  Per $1,000 of Face Amount
               ("Appendix E") by (ii) the Initial Face Amount, and then dividing
               by 1000.

               EXAMPLE.  The  following  example  illustrates  how the Surrender
               Charge is determined. Assume that a male nonsmoker, Age 35 buys a
               Policy with an initial Face Amount of $100,000 and he  surrenders
               the Policy during the third Policy Year at which time he has paid
               cumulative premiums of $2,000.

               Based on  these  assumptions  the  Surrender  Charge  will be the
               result of  multiplying  (i)  $16.20  (from  Appendix D for a male
               nonsmoker  Age 35) by (ii) $100,000 (the Initial Face Amount) and
               by (iii)  100%  (the  applicable  percentage  from the  Surrender
               Charge  Percentage  Table),  and then  dividing  by  1000,  which
               results in a Surrender Charge of $1,620 ($16.20 x $100,000 x 100%
               / 1000).

               The  Surrender   Charge  Whole  Life  Premium  is  determined  by
               multiplying  (i) $11.64 (from Appendix E for a male nonsmoker Age
               35) by (ii) $100,000 (the Initial Face Amount), and then dividing
               by 1000,  which results in a Surrender  Charge Whole Life Premium
               of $1,164 ($11.64 x $100,000 / 1000).  The Surrender Charge Whole
               Life  Premium  of $1,164 is less than the  cumulative  premium of
               $2,000,  so the Premium  Related  Surrender  Charge  Reduction is
               zero.

               The additional  Surrender Charge for requested  increases in Face
               Amount will be  calculated in the same manner as  illustrated  in
               the example  above,  except that the  Premium  Related  Surrender
               Charge is zero for requested increases in Face Amount.


                        SURRENDER CHARGE PERCENTAGE TABLE

 IF SURRENDER OR LAPSE OCCURS IN THE LAST        THE FOLLOWING PERCENTAGE OF THE
          MONTH OF POLICY YEAR:*             SURRENDER CHARGE WILL BE PAYABLE:**
          ----------------------             -----------------------------------
                 1 through 5                                    100%
                      6                                         90%
                      7                                         80%
                      8                                         70%
                      9                                         60%
                     10                                         50%
                     11                                         40%
                     12                                         30%
                     13                                         20%
                     14                                         10%
                15 and later                                     0%

*    For requested increases, years are measured from the date of the increase.

**   The  percentages  reduce  equally  for each Policy  Month  during the years
     shown. For example,  during the seventh Policy Year, the percentage reduces
     equally  each month from 90% at the end of the sixth  Policy Year to 80% at
     the end of the seventh Policy Year.

                    (4)  CUMULATED OR REINVESTED DISTRIBUTIONS OR INCOME

               All income and other distributions earned by the Variable Account
               are reinvested,  without charge,  at net asset value in shares of
               the Fund making the distribution.

               (5)  REDEEMED OR LIQUIDATED ASSETS OF THE TRUST'S SECURITIES

          No load,  fee,  expense  or  charge is  assessed  in  connection  with
          redemptions.

     (b)  FOR EACH INSTALLMENT PAYMENT TYPE OF PERIODIC PAYMENT PLAN CERTIFICATE
          OF THE TRUST, FURNISH THE FOLLOWING  INFORMATION WITH RESPECT TO SALES
          LOAD AND OTHER DEDUCTIONS FROM PRINCIPAL PAYMENTS.

          See the answers to Items 13(a) and 13(d).

     (c)  STATE (1) THE AMOUNT OF SALES LOAD AS A  PERCENTAGE  OF THE NET AMOUNT
          INVESTED,  AND (2) THE AMOUNT OF TOTAL  DEDUCTIONS  AS A PERCENTAGE OF
          THE NET AMOUNT INVESTED FOR EACH TYPE OF SECURITY ISSUED BY THE TRUST.

          See the answer to Item 13(a).

     (d)  FURNISH A BRIEF  DESCRIPTION OF ANY LOADS,  FEES,  EXPENSES OR CHARGES
          NOT  COVERED IN ITEM 13(A)  WHICH MAY BE PAID BY  SECURITY  HOLDERS IN
          CONNECTION WITH THE TRUST OR ITS SECURITIES.

          MONTHLY  DEDUCTION.  RBSL deducts the charges described below from the
          Accumulation  Value of the  Policy  on a monthly  basis.  The total of
          these charges is called the Monthly Deduction.

          The Monthly  Deduction  will be deducted on each  Monthly  Anniversary
          from the Fixed Account and the Sub-Accounts of the Variable Account on
          a proportionate basis depending on their relative  Accumulation Values
          at that time. For purposes of determining these proportions, the Fixed
          Accumulation Value is reduced by the Loan Amount.  Because portions of
          the Monthly  Deduction,  such as the cost of insurance,  can vary from
          month to month, the Monthly  Deduction itself will vary in amount from
          month to month.

          If the Cash  Surrender  Value is not  sufficient  to cover the Monthly
          Deduction on a Monthly Anniversary, the Policy may lapse.

               COST OF  INSURANCE.  RBSL  will  determine  the  monthly  cost of
               insurance by multiplying the applicable cost of insurance rate or
               rates by the net amount at risk under the Policy.  The net amount
               at risk  under  the  Policy  for a Policy  Month is (a) the Death
               Benefit at the  beginning of the Policy Month divided by 1.004074
               (which  reduces  the net amount at risk,  solely for  purposes of
               computing the cost of insurance,  by taking into account  assumed
               monthly  earnings  at  an  annual  rate  of  5%),  less  (b)  the
               Accumulation Value at the beginning of the Policy Month minus any
               charges  for rider  benefits,  other  than any  Waiver of Monthly
               Deduction rider, for the month.

               The  net  amount  at  risk  may be  affected  by  changes  in the
               Accumulation Value or in the Face Amount. If there is an increase
               in the Face Amount and the Rate Class  applicable to the increase
               is  different  from that for the  initial  Face  Amount,  the net
               amount at risk will be calculated separately for each Rate Class.
               RBSL groups  insureds into a Rate Class based on its  expectation
               that they will have similar mortality experience. For purposes of
               determining  the net  amount  at risk for each  Rate  Class,  the
               Accumulation Value will first be considered a part of the initial
               Face  Amount.  If the  Accumulation  Value  is  greater  than the
               initial  Face Amount,  it will then be  considered a part of each
               increase in order, starting with the first increase.

               Cost of  insurance  rates will be based on the sex,  attained age
               and Rate  Class(es)  of the insured.  The actual  monthly cost of
               insurance rates will be based on RBSL's expectations as to future
               experience.   They  will  not,  however,   be  greater  than  the
               guaranteed cost of insurance rates shown in the Policy, which are
               based on the Commissioners 1980 Standard Ordinary Mortality Table
               and the insured's attained age at the last birthday.

               MONTHLY   ADMINISTRATIVE  CHARGE.  Each  month  RBSL  deducts  an
               administrative charge of $7.50 per $1,000 of Face Amount which is
               guaranteed not to exceed $10 each month.  This charge  reimburses
               RBSL for expenses incurred in administering  the Policy,  such as
               processing claims, maintaining records, making Policy changes and
               communicating with owners of Policies.

               MONTHLY  MORTALITY  AND  EXPENSE  RISK  CHARGE.  Each month it is
               currently  anticipated  that RBSL will  deduct  this charge at an
               annual  rate of .75 of 1%  (.75%)  of the  Variable  Accumulation
               Value but in no event will it exceed .9 of 1% (.90%).

               OPTIONAL  INSURANCE  BENEFIT  CHARGES.  Each month  RBSL  deducts
               charges for any optional  insurance  benefits added to the Policy
               by rider.

          CHARGES AGAINST THE VARIABLE ACCOUNT. Certain charges will be deducted
          as a percentage of the value of the net assets of the Variable Account
          to compensate RBSL as for certain risks assumed in connection with the
          Policy.  These  charges will not be deducted  from assets in the Fixed
          Account.

          Currently no charge is made to the Variable Account for federal income
          taxes that may be  attributable  to the  Variable  Account.  RBSL may,
          however, make such a charge in the future. Charges for other taxes, if
          any, attributable to the Variable Account may also be made.

          Because the Variable  Account  purchases  shares of the Funds, the net
          asset value of the  investments  of the Variable  Account will reflect
          the investment advisory fees and other expenses incurred by the Funds.

          Set forth below is information provided by each Fund on its total 1996
          annual expenses as a percentage of the Fund's average net assets.  For
          more information  concerning these expenses,  see the prospectuses for
          the Funds that accompany this Prospectus.

<TABLE>
<CAPTION>

                                                                                                TOTAL INVESTMENT
                                                                MANAGEMENT          OTHER          FUND ANNUAL
                                                                   FEES           EXPENSES          EXPENSES
                                                                   ----           --------          --------
<S>                                                              <C>                <C>              <C>  
VIP Money Market Portfolio........................................0.21%             0.09%            0.30%
VIP High Income Portfolio ........................................0.59%             0.12%            0.71%
VIP Equity-Income Portfolio (a)...................................0.51%             0.07%            0.58%
VIP Growth Portfolio (a)..........................................0.61%             0.08%            0.69%

                                                                                                TOTAL INVESTMENT
                                                                MANAGEMENT          OTHER          FUND ANNUAL
                                                                   FEES           EXPENSES          EXPENSES
                                                                   ----           --------          --------
VIP Overseas Portfolio (a)........................................0.76%             0.17%            0.93%

VIP II Asset Manager Portfolio (a)................................0.64%             0.10%            0.74%
VIP II Investment Grade Bond Portfolio............................0.45%             0.13%            0.58%
VIP II Index 500 Portfolio (b)....................................0.13%             0.15%            0.28%
VIP II Contrafund Portfolio (a)...................................0.61%             0.13%            0.74%

Northstar Income and Growth Fund (c)..............................0.75%             0.05%            0.80%
Northstar Multi-Sector Bond Fund (c)..............................0.75%             0.05%            0.80%

Putnam VT Diversified Income Fund.................................0.70%             0.13%            0.83%
Putnam VT Growth and Income Fund..................................0.49%             0.05%            0.54%
Putnam VT Utilities Growth and Income Fund (d)....................0.69%             0.09%            0.78%
Putnam VT Voyager Fund............................................0.57%             0.06%            0.63%
Putnam VT Asia Pacific Growth Fund................................0.80%             0.43%            1.23%
Putnam VT New Opportunities Fund..................................0.63%             0.09%            0.72%

</TABLE>

     (a)  During 1996, a portion of the brokerage commissions that certain funds
          pay was used to reduce  funds'  expenses.  In addition,  certain funds
          have entered into arrangements with their custodian and transfer agent
          whereby interest earned on uninvested cash balances was used to reduce
          custodian and transfer agent expenses. Including these reductions, the
          total  operating  expenses  would  have  been .56% for  Equity  Income
          Portfolio,  .67% for Growth  Portfolio,  .92% for Overseas  Portfolio,
          .73% for Asset Manager Portfolio,  and .71% for Contrafund  Portfolio.
          For more information on the funds'  Management Fees and Expenses,  see
          the prospectus for the Fund.

     (b)  During  1996,  the  investment  adviser  to the  Index  500  Portfolio
          reimbursed   a  portion   of  the   fund's   expenses.   Without   the
          reimbursement,  the fund's  management  fee,  other expenses and total
          expenses would have been .28%, .15%, and .43%, respectively.  For more
          information  on the  fund's  Management  Fees  and  Expenses,  see the
          prospectus for the Fund.

     (c)  The investment  adviser to the Northstar  Variable Trust has agreed to
          reimburse the two Northstar  Funds for any expenses in excess of 0.80%
          of each  Fund's  average  daily  net  assets.  In the  absence  of the
          investment adviser's expense reimbursements,  the actual expenses that
          would  have  been paid by each  Fund  during  its  fiscal  year  ended
          December 31, 1996 would have been 1.40% for Income and Growth Fund and
          1.68% for Multi-Sector Bond Fund.

     (d)  On July  11,  1996,  shareholders  approved  an  increase  in the fees
          payable to Putnam Investment  Management,  Inc. ("Putnam  Management")
          under the  management  contract  for  Putnam VT  Utilities  Growth and
          Income Fund. The management fees and total expenses shown in the table
          have been restated to reflect the increase. Actual management fees and
          total expenses were 0.64% and 0.73%, respectively.

          PARTIAL WITHDRAWAL AND TRANSFER CHARGES

          RBSL  currently  make no charge for  transfers.  It  currently  charge
          $10.00  for each  partial  withdrawal.  The charge  for  transfers  is
          guaranteed  not to exceed  $25.00 per transfer for transfers in excess
          of 12 per Policy Year for the  duration of the Policy.  The charge for
          partial  withdrawals  is  guaranteed  not to  exceed  $25.00  for  the
          duration of the  Policy.  The  transfer  charge will not be imposed on
          transfers  that occur as a result of Policy  loans or the  exercise of
          conversion rights.

     (e)  STATE  WHETHER THE  DEPOSITOR,  PRINCIPAL  UNDERWRITER,  CUSTODIAN  OR
          TRUSTEE,  OR ANY  AFFILIATED  PERSON  OF THE  FOREGOING,  MAY  RECEIVE
          PROFITS  OR OTHER  BENEFITS  NOT  INCLUDED  IN ANSWER TO ITEM 13(A) OR
          13(D)  THROUGH  THE SALE OR  PURCHASE  OF THE  TRUST'S  SECURITIES  OR
          INTEREST IN SUCH SECURITIES,  OR UNDERLYING SECURITIES OR INTERESTS IN
          UNDERLYING  SECURITIES,  AND  DESCRIBE  FULLY THE NATURE AND EXTENT OF
          SUCH PROFITS OR BENEFITS.

          There is no trustee.  Neither RBSL as custodian or depositor,  nor the
          Distributor as principal  underwriter,  nor any  affiliated  person of
          RBSL or of the  Distributor,  will receive  profits or other  benefits
          from premium  payments under the Policies or the  investments  held in
          the  Variable  Account not  included in the answers to Items 13(a) and
          13(d)  through the sale or  purchase of the  Policies or shares of the
          Fund, except that (1) RBSL may receive a profit to the extent that the
          cost of  insurance  built into a Policy  exceeds  the  actual  cost of
          insurance  needed to pay the  benefits,  (2)  favorable  mortality  or
          expense  experience may cause the insurance provided under a Policy to
          be profitable to RBSL, (3) RBSL and/or the Distributor will compensate
          certain  other persons for services  rendered in  connection  with the
          distribution  of a Policy,  as described in the answer to Item 38, but
          such  payments  will be made from  RBSL's  general  account  or by the
          Distributor,  as  the  case  may  be,  and  (4)  Northstar  Investment
          Management Corporation will receive an advisory fee from the currently
          available Funds, as described in the answer to Item 13(a).

     (f)  STATE THE PERCENTAGE THAT THE AGGREGATE  ANNUAL CHARGES AND DEDUCTIONS
          FOR  MAINTENANCE  AND OTHER EXPENSES OF THE TRUST BEAR TO THE DIVIDEND
          AND INTEREST  INCOME FROM THE TRUST PROPERTY DURING THE PERIOD COVERED
          BY THE FINANCIAL STATEMENTS FILED HEREWITH.

          The Variable Account has not yet commenced operations.

     INFORMATION CONCERNING THE OPERATIONS OF THE TRUST

     14.  DESCRIBE THE PROCEDURE WITH RESPECT TO THE  APPLICATIONS  (IF ANY) AND
          THE ISSUANCE AND AUTHENTICATION OF THE TRUST'S  SECURITIES,  AND STATE
          THE  SUBSTANCE  OF  THE  PROVISIONS  OF  ANY  INDENTURE  OR  AGREEMENT
          PERTAINING THERETO.

          The Policies will be offered and sold pursuant to established  premium
          schedules and  underwriting  standards  and in  accordance  with state
          insurance laws. Such laws prohibit unfair  discrimination among Policy
          owners, but recognize that premiums must be based upon factors such as
          age,  sec,  health and  occupation.  A person  desiring  to purchase a
          Policy must complete an application  on a form provided by RBSL,  and,
          if the  applicant  meets the  prescribed  standards,  a Policy will be
          issued.   This  process  may  involve  such   procedures   as  medical
          examinations  and may require  that  further  information  be provided
          before a determination can be made.

     15.  DESCRIBE THE  PROCEDURE  WITH RESPECT TO THE RECEIPT OF PAYMENTS  FROM
          PURCHASERS OF THE TRUST'S  SECURITIES AND THE HANDLING OF THE PROCEEDS
          THEREOF, AND STATE THE SUBSTANCE OF THE PROVISIONS OF ANY INDENTURE OR
          AGREEMENT PERTAINING THERETO.

          See the answer to Item 10(i) with regard to the payment and allocation
          of premiums.

          Individuals  wishing to  purchase a Policy  must make  application  to
          RBSL. A Policy will be issued only to insureds who supply satisfactory
          evidence  of  insurability  to RBSL.  Acceptance  is subject to RBSL's
          underwriting   rules  and  RBSL   reserves  the  right  to  reject  an
          application for any reason.

          When an  application  for a Policy is  completed,  it is  submitted to
          RBSL. RBSL performs suitability and insurance underwriting reviews and
          determines  whether to accept or reject the application for the Policy
          and the insured's risk classification. If a Policy is not issued, RBSL
          will refund any premium that has been paid in advance.

     16.  DESCRIBE THE PROCEDURE  WITH RESPECT TO THE  ACQUISITION OF UNDERLYING
          SECURITIES AND THE DISPOSITION THEREOF, AND STATE THE SUBSTANCE OF THE
          PROVISIONS OF ANY INDENTURE OR AGREEMENT PERTAINING THERETO.

          The assets of each Sub-Account of the Variable Account are invested in
          shares  of one of the Funds at their net  asset  value  next  computed
          after receipt of the purchase order. Similarly, the Funds redeem their
          shares at net asset value next  computed  after receipt of the request
          for  redemption.  The  value  of the  assets  of each of the  Funds is
          determined  as of the  close of the New York  Stock  Exchange  on each
          Valuation Date.

     17.  (a)  DESCRIBE THE PROCEDURE WITH RESPECT TO WITHDRAWAL OR REDEMPTION 
               BY SECURITY HOLDERS.

               See the answers to Items 10(c), 10(d), 10(e) and 10(i).

          (b)  FURNISH THE NAMES OF ANY PERSONS WHO MAY REDEEM OR REPURCHASE, OR
               ARE REQUIRED TO REDEEM OR REPURCHASE,  THE TRUST'S  SECURITIES OR
               UNDERLYING  THE  SECURITIES  FROM  SECURITY   HOLDERS,   AND  THE
               SUBSTANCE  OF  THE  PROVISIONS  OF  ANY  INDENTURE  OR  AGREEMENT
               PERTAINING THERETO.

               RBSL is required by the terms of the  Policies to honor  requests
               for redemption where permitted.  RBSL causes redemption of shares
               of the Funds held by the  Variable  Account as  necessary to make
               payments from the assets of the Variable Account.

          (c)  INDICATE  WHETHER  REPURCHASED  OR  REDEEMED  SECURITIES  WILL BE
               CANCELED OR MAY BE RESOLD.

               Upon termination, a Policy may not be resold.

     18.  (a)  DESCRIBE THE  PROCEDURE  WITH RESPECT TO THE RECEIPT, CUSTODY AND
               DISPOSITION OF THE INCOME AND OTHER  DISTRIBUTABLE  FUNDS OF THE 
               TRUST AND STATE  THE SUBSTANCE OF THE PROVISIONS OF ANY INDENTURE
               OR AGREEMENT PERTAINING THERETO.

               Distributions  in respect of the shares of each of the Funds held
               by the Variable  Account are reinvested in shares of that Fund at
               net asset  value,  which  shares  are added to the  assets of the
               appropriate Sub-Account of the Variable Account.

          (b)  DESCRIBE THE PROCEDURE,  IF ANY, WITH RESPECT TO THE REINVESTMENT
               OF  DISTRIBUTIONS  TO SECURITY HOLDERS AND STATE THE SUBSTANCE OF
               THE PROVISIONS OF ANY INDENTURE OR AGREEMENT PERTAINING THERETO.

               Not applicable. See the answer to Item 18(a).

          (c)  IF ANY  RESERVES  OR SPECIAL  FUNDS ARE  CREATED OUT OF INCOME OR
               PRINCIPAL,  STATE WITH  RESPECT TO EACH SUCH  RESERVE OR FUND THE
               PURPOSE AND ULTIMATE DISPOSITION THEREOF, AND DESCRIBE THE MANNER
               OF HANDLING OF SAME.

               Net Premiums placed in the Variable Account  constitute  reserves
               for benefits under the Policies.

          (d)  SUBMIT A SCHEDULE SHOWING THE PERIODIC AND SPECIAL  DISTRIBUTIONS
               WHICH HAVE BEEN MADE TO SECURITY  HOLDERS  DURING THE THREE YEARS
               COVERED BY THE FINANCIAL  STATEMENTS  FILED  HEREWITH.  STATE FOR
               EACH SUCH DISTRIBUTION THE AGGREGATE AMOUNT AND AMOUNT PER SHARE.
               IF DISTRIBUTIONS FROM SOURCES OTHER THAN CURRENT INCOME HAVE BEEN
               MADE,  IDENTIFY EACH SUCH OTHER SOURCE AND INDICATE  WHETHER SUCH
               DISTRIBUTION  REPRESENTS  THE  RETURN OF  PRINCIPAL  PAYMENTS  TO
               SECURITY HOLDERS. IF PAYMENTS OTHER THAN CASH WERE MADE, DESCRIBE
               THE  NATURE  THEREOF,  THE  ACCOUNT  CHARGED  AND  THE  BASIS  OF
               DETERMINING THE AMOUNT OF SUCH CHARGE.

               The Variable Account has not yet commenced operations.

     19.  DESCRIBE  THE  PROCEDURE  WITH  RESPECT TO THE  KEEPING OF RECORDS AND
          ACCOUNTS  OF THE TRUST,  THE MAKING OF REPORTS AND THE  FURNISHING  OF
          INFORMATION TO SECURITY  HOLDERS,  AND THE SUBSTANCE OF THE PROVISIONS
          OF ANY INDENTURE OR AGREEMENT PERTAINING THERETO.

          RBSL will maintain all records relating to the Variable Account.  RBSL
          will mail to Policy owners at their last known  address of record,  at
          least annually,  reports setting forth,  among other things,  the Face
          Amount, Death Benefit,  Accumulation Value, Cash Surrender Value, Loan
          Amount,  premiums paid, Planned Periodic  Premiums,  interest credits,
          partial  withdrawals,  transfers,  and charges  since the last report.
          Additional  reports are available  for a fee upon  request.  Also upon
          request,  RBSL will for a fee  provide  to the  Policy  owner a report
          projecting  future results based on the Death Benefit Option specified
          by the owner,  the Planned Periodic  Premiums  specified by the owner,
          and the  Accumulation  Value  of the  Policy  at the end of the  prior
          Policy year.  Each Policy owner will also be sent an annual report for
          the Variable  Account and a list of the portfolio  securities  held in
          each series of the Fund, as required by the Investment  Company Act of
          1940.

     20.  STATE THE  SUBSTANCE OF THE  PROVISIONS  OF ANY INDENTURE OR AGREEMENT
          CONCERNING THE TRUST WITH RESPECT TO THE FOLLOWING:

          (a)  AMENDMENTS TO SUCH INDENTURE OR AGREEMENT.

               Not applicable.

          (b)  THE EXTENSION OR TERMINATION OF SUCH INDENTURE OR AGREEMENT.

               Not applicable.

          (c)  THE REMOVAL OR  RESIGNATION  OF THE TRUSTEE OR CUSTODIAN,  OR THE
               FAILURE  OF THE  TRUSTEE OR  CUSTODIAN  TO  PERFORM  ITS  DUTIES,
               OBLIGATIONS AND FUNCTIONS.

               There is no such  indenture or agreement and  accordingly no such
               provision.

          (d)  THE  APPOINTMENT  OF A SUCCESSOR  TRUSTEE AND THE  PROCEDURE IF A
               SUCCESSOR TRUSTEE IS NOT APPOINTED.

               The Variable Account has no trustee.

          (e)  THE REMOVAL OR RESIGNATION  OF THE  DEPOSITOR,  OR THE FAILURE OF
               THE DEPOSITOR TO PERFORM ITS DUTIES, OBLIGATIONS AND FUNCTIONS.

               There is no such  indenture or agreement and  accordingly no such
               provision.

          (f)  THE  APPOINTMENT OF A SUCCESSOR  DEPOSITOR AND THE PROCEDURE IF A
               SUCCESSOR DEPOSITOR IS NOT APPOINTED.

               There is no such  indenture or agreement and  accordingly no such
               provision.

     21.  (a)  STATE  THE  SUBSTANCE  OF  THE  PROVISIONS  OF ANY  INDENTURE  OR
               AGREEMENT WITH RESPECT TO LOANS TO SECURITY HOLDERS.

               POLICY LOANS.  After the first Policy Year,  the Policy owner may
               borrow up to the Loan Value of the Policy,  which is equal to the
               Cash Value less the existing  Loan  Amount.  Each loan must be at
               least $500.

               RBSL  makes  loans  from the  Fixed  Accumulation  Value  and the
               Variable   Accumulation  Value  on  a  proportionate  basis.  For
               purposes of determining the  proportions,  the  outstanding  Loan
               Amount is subtracted from the Fixed Accumulation Value.

               The total of outstanding loans and unpaid loan interest is called
               the  Loan  Amount.   Loan  Amounts  do  not  participate  in  the
               investment  performance  of the Funds.  However,  RBSL  currently
               credits 4% interest on the Loan Amount. If, at any time, the Loan
               Amount is  greater  than the  Accumulation  Value  reduced by the
               applicable  Surrender  Charge,  the Policy will lapse unless RBSL
               receives a sufficient payment during the 61 day grace period.

               A loan may cause termination of the Death Benefit Guarantee.  The
               Loan  Amount  is  deducted   from  the  total   premium  paid  in
               calculating the Minimum Premium Requirement for the Death Benefit
               Guarantee.

               RBSL  deducts any Loan Amount  from the  proceeds  when it pays a
               claim.

               RBSL  charges  interest  on the Loan  Amount at an annual rate of
               5.66%,  payable in advance for each year.  After the tenth Policy
               Year,  RBSL will  charge  interest  at an  annual  rate of 3.85%,
               payable in advance. If interest is not paid when due, it is added
               to the Loan Amount.

               The Policy owner may repay all or part of any Loan Amount  during
               the  insured's  lifetime.  When the owner  makes a  payment  on a
               Policy loan, to avoid a Premium Expense Charge on the payment the
               owner must tell RBSL that it is a loan repayment. Loan repayments
               are credited to the Fixed Account and the Variable Account in the
               form of Net  Premiums  without a  Premium  Expense  Charge.  RBSL
               credits Policy loan  repayments  according to the current premium
               allocation.

               When there is an outstanding Policy loan, RBSL reserves the right
               to consider any payments it receives, planned or unscheduled,  as
               Policy loan repayments and not as premium payments.

          (b)  FURNISH A BRIEF  DESCRIPTION  OF ANY PROCEDURE OR  ARRANGEMENT BY
               WHICH  LOANS  ARE  MADE  AVAILABLE  TO  SECURITY  HOLDERS  BY THE
               DEPOSITOR,  PRINCIPAL UNDERWRITER,  TRUSTEE OR CUSTODIAN,  OR ANY
               AFFILIATED PERSON OF THE FOREGOING.

               See the answer to Item 21(a).

          (c)  IF SUCH LOANS ARE MADE,  FURNISH  THE  AGGREGATE  AMOUNT OF LOANS
               OUTSTANDING  AT THE END OF THE LAST  FISCAL  YEAR,  THE AMOUNT OF
               INTEREST  COLLECTED  DURING THE LAST FISCAL YEAR ALLOCATED TO THE
               DEPOSITOR,   PRINCIPAL  UNDERWRITER,   TRUSTEE  OR  CUSTODIAN  OR
               AFFILIATED  PERSON OF THE FOREGOING  AND THE AGGREGATE  AMOUNT OF
               LOANS IN DEFAULT AT THE END OF THE LAST  FISCAL  YEAR  COVERED BY
               FINANCIAL STATEMENTS FILED HEREWITH.

               The Variable Account has not yet commenced operations.

     22.  STATE THE  SUBSTANCE OF THE  PROVISIONS  OF ANY INDENTURE OR AGREEMENT
          WITH  RESPECT TO  LIMITATIONS  ON THE  LIABILITIES  OF THE  DEPOSITOR,
          TRUSTEE  OR  CUSTODIAN,  OR ANY  OTHER  PARTY  TO  SUCH  INDENTURE  OR
          AGREEMENT.

          See the answer to Item 10(e) for a  description  of the  provisions of
          the Policies relating to lapse.

          For any  assignment of a Policy to be binding on RBSL, it must receive
          written notice of the assignment.  RBSL assumes no responsibility  for
          the  validity  of any  assignment  or  the  extent  of the  assignee's
          interest.

          If the  insured's  age or sex is misstated in the Policy  application,
          RBSL  adjusts  the  proceeds  by the  difference  between  the Monthly
          Deductions made and those that should have been made.

          If RBSL  makes  incorrect  payments  because of  incorrect  age or sex
          information, or any error or miscalculation,  it adjusts the proceeds.
          RBSL  deducts any  overpayments  from the next  payment or payments or
          requests a refund of the  overpayment.  It adds  underpayments  to the
          next payment or pays the owner that amount  immediately.  In adjusting
          the  proceeds  RBSL uses the  interest  rates in effect  for the Fixed
          Accumulation  Value and the applicable  Sub-Account Unit Values at the
          time the Monthly  Deduction,  error or  miscalculation  was originally
          made.

          If the insured  commits  suicide  within two years of the Policy Date,
          RBSL does not pay the Death Benefit.  Instead, it refunds all premiums
          paid for the Policy and any  attached  riders,  minus any Loan Amounts
          and  partial  withdrawals.  If the Policy  owner  makes a Face  Amount
          increase or a premium  payment which requires  proof of  insurability,
          the corresponding  Death Benefit increase has its own two-year suicide
          limitation  for the proceeds  associated  with that  increase.  If the
          insured  commits suicide within two years of the effective date of the
          increase,  RBSL  pays the  Death  Benefit  prior to the  increase  and
          refunds the cost of insurance for that increase.

          Payments from the Variable Account for Death Benefits, cash surrender,
          partial  withdrawal or loans will be made within seven days after RBSL
          received all the documents required for the payments.

          However,  RBSL  may  delay  making  a  payment  when it is not able to
          determine the Variable Accumulation Value because:

               - The New York Stock Exchange is closed for trading, or
               - The SEC determines that a state of emergency exists.

          Payments  from the Fixed  Account may be delayed up to six months from
          the date RBSL receives the documents required.  RBSL will pay interest
          at an effective  annual rate of 3-1/2% if it delays  payment more than
          30 days.

     23.  DESCRIBE ANY BONDING ARRANGEMENT FOR OFFICERS,  DIRECTORS, PARTNERS OR
          EMPLOYEES  OF THE  DEPOSITOR OR  PRINCIPAL  UNDERWRITER  OF THE TRUST,
          INCLUDING THE AMOUNT OF COVERAGE AND THE TYPE OF BOND.

          An insurance company blanket bond is maintained providing  $25,000,000
          coverage for officers,  employees,  general  agents and agents of RBSL
          and the Distributor, subject to a $100,000 deductible.

     24.  STATE THE SUBSTANCE OF ANY OTHER MATERIAL  PROVISIONS OF ANY INDENTURE
          OR AGREEMENT  CONCERNING THE TRUST OR ITS SECURITIES AND A DESCRIPTION
          OF ANY OTHER MATERIAL FUNCTIONS OR DUTIES OF THE DEPOSITOR, TRUSTEE OR
          CUSTODIAN NOT STATED IN ITEM 10 OR ITEMS 14 TO 23 INCLUSIVE.

          After the Policy has been in force during the  insured's  lifetime for
          two years from the Policy  Date,  RBSL cannot claim the Policy is void
          or refuse to pay any proceeds unless the Policy has lapsed.

          If the Policy owner makes a Face Amount  increase or a premium payment
          which requires proof of insurability,  the corresponding Death Benefit
          increase has its own two-year  contestable  period  measured  from the
          date of the increase.

          If the Policy is reinstated,  the contestable  period is measured from
          the date of  reinstatement  with  respect  to  statements  made on the
          application for reinstatement.

III. ORGANIZATION, PERSONNEL AND AFFILIATED PERSONS OF DEPOSITOR

          ORGANIZATION AND OPERATIONS OF DEPOSITOR

     25.  STATE THE FORM OF ORGANIZATION OF THE DEPOSITOR OF THE TRUST, THE NAME
          OF THE  STATE OR OTHER  SOVEREIGN  POWER  UNDER  THE LAWS OF WHICH THE
          DEPOSITOR WAS ORGANIZED AND THE DATE OF organization.

          RBSL is a stock life insurance company which was organized in 1917 and
          incorporated under the laws of New York.

     26.  (a)  FURNISH  THE  FOLLOWING  INFORMATION  WITH  RESPECT  TO ALL  FEES
               RECEIVED BY THE DEPOSITOR OF THE TRUST IN CONNECTION WITH THE 
               EXERCISE OF ANY FUNCTIONS OR DUTIES  CONCERNING  SECURITIES 
               OF THE TRUST DURING THE PERIOD COVERED BY THE FINANCIAL 
               STATEMENTS FILED HEREWITH.

               RBSL has not yet received any such fees.

          (b)  FURNISH THE FOLLOWING  INFORMATION WITH RESPECT TO ANY FEE OR ANY
               PARTICIPATION   IN  FEES  RECEIVED  BY  THE  DEPOSITOR  FROM  ANY
               UNDERLYING   INVESTMENT  COMPANY  OR  ANY  AFFILIATED  PERSON  OR
               INVESTMENT ADVISER OF SUCH COMPANY.

               (1)  THE NATURE OF SUCH FEE OR PARTICIPATION.

               (2)  THE NAME OF THE PERSON MAKING PAYMENTS.

               (3)  THE NATURE OF THE  SERVICES  RENDERED IN  CONSIDERATION  FOR
                    SUCH FEE OR PARTICIPATION.

               (4)  THE AGGREGATE  AMOUNT  RECEIVED  DURING THE LAST FISCAL YEAR
                    COVERED BY THE FINANCIAL STATEMENTS FILED HEREWITH.

               RBSL has not  received,  and will not receive,  any fees from the
               Funds,  or from any affiliated  persons of the Funds, or from any
               investment adviser of the Funds.

     27.  DESCRIBE  THE  GENERAL  CHARACTER  OF THE  BUSINESS  ENGAGED IN BY THE
          DEPOSITOR  INCLUDING A STATEMENT AS TO ANY BUSINESS OTHER THAN THAT OF
          DEPOSITOR  OF THE  TRUST.  IF THE  DEPOSITOR  ACTS OR HAS ACTED IN ANY
          CAPACITY  WITH RESPECT TO ANY  INVESTMENT  COMPANY OR COMPANIES  OTHER
          THAN THE TRUST,  STATE THE NAME OR NAMES OF SUCH COMPANY OR COMPANIES,
          THEIR  RELATIONSHIP,  IF ANY,  TO THE  TRUST,  AND THE  NATURE  OF THE
          DEPOSITOR'S  ACTIVITIES THEREWITH.  IF THE DEPOSITOR HAS CEASED TO ACT
          IN  SUCH  NAMED  CAPACITY,   STATE  THE  DATE  OF  AND   CIRCUMSTANCES
          SURROUNDING SUCH CESSATION.

          RBSL  offers a variety of  individual  life and health  insurance  and
          annuities, group life and health insurance.

          RBSL presently  offers  individual  variable annuity and variable life
          contracts with benefits  which vary in accordance  with the investment
          results of Separate Accounts of RBSL.

          OFFICIALS AND AFFILIATED PERSONS OF DEPOSITOR

     28.  (a)  FURNISH AS AT LATEST PRACTICABLE  DATE THE FOLLOWING  INFORMATION
               WITH  RESPECT  TO THE DEPOSITOR  OF THE TRUST,  WITH  RESPECT TO 
               EACH OFFICER, DIRECTOR OR PARTNER OF THE DEPOSITOR, AND WITH  
               RESPECT TO EACH NATURAL PERSON DIRECTLY OR INDIRECTLY  OWNING,  
               CONTROLLING OR HOLDING WITH POWER TO VOTE 5% OR MORE OF THE  
               OUTSTANDING VOTING SECURITIES OF THE DEPOSITOR.

               See the  answer to Item  28(b)  for  information  concerning  the
               names,  addresses  and business  experience  during the last five
               years of the  executive  officers  and  directors  of RBSL.  With
               respect to ownership of stock of RBSL, see the answer to Item 29.

          (b)  FURNISH A BRIEF STATEMENT OF THE BUSINESS  EXPERIENCE  DURING THE
               LAST FIVE  YEARS OF EACH  OFFICER,  DIRECTOR  OR  PARTNER  OF THE
               DEPOSITOR.

Directors and Officers

<TABLE>
<CAPTION>

NAME AND PRINCIPAL  
 BUSINESS ADDRESS                              PRINCIPAL OCCUPATION AND BUSINESS EXPERIENCE
 ----------------                              --------------------------------------------
<S>                                    <C> 
Susan M. Bergen                        Secretary  of  ReliaStar  Bankers  Security  Life  Insurance
20 Washington Ave. So.                 Company.  Attorney for ReliaStar Life Insurance  Company for
Minneapolis, MN  55401                 more than five years.                                       
                                       
Stephen A. Carb*                       Partner of Carb, Luria,  Glassner,  Cook & Kufeld (law firm)
529 5th Ave. 7th Floor                 since 1962.                                                 
New York, NY  10017                    

James Cochran**                        Executive Vice President of ReliaStar  Bankers Security Life
1000 Woodbury Rd, #102                 Insurance  Company since 1996;  Executive Vice President and
Woodbury, NY  11797                    Chief  Operating  Officer of ReliaStar  United Services Life
                                       Insurance   Company   ("RUSL")   since  1996:   Senior  Vice
                                       President,  Product  Development  and Strategic  Planning of
                                       RUSL  from  1995 to 1996;  Senior  Vice  President,  Product
                                       Development from 1990 to 1995.                              
                                       
R. Michael Conley***                   Senior Vice  President of ReliaStar  Financial  Corp.  since
20 Washington Ave. So.                 1991; Senior Vice President,  ReliaStar Employee Benefits of
Minneapolis, MN  55401                 ReliaStar  Life Insurance  Company since 1986;  President of
                                       NWNL  Benefits   Corporation  since  1988;   Executive  Vice
                                       President  of  ReliaStar  Bankers  Security  Life  Insurance
                                       Company  since  1996;  Director of various  subsidiaries  of
                                       ReliaStar Financial Corp.                                   
                                       
Richard R. Crowl***                    Senior Vice  President,  General  Counsel and  Secretary  of
20 Washington Ave. So.                 ReliaStar  Financial Crop. since 1996; Senior Vice President
Minneapolis, MN  55401                 and General  Counsel of ReliaStar  Life  Insurance  Company,
                                       ReliaStar Bankers Security Life Insurance Company,  Northern
                                       Life Insurance  Company,  and ReliaStar United Services Life
                                       Insurance  Company since 1996;  Executive Vice President and
                                       General Counsel of Washington  Square  Advisers,  Inc. since
                                       1986;  Vice  President  and  Associate  General  Counsel  of
                                       ReliaStar  Financial Corp. from 1989 to 1996; Vice President
                                       and Associate  General  Counsel of ReliaStar  Life Insurance
                                       Company  from  1985  to  1996;   Director  and  Senior  Vice
                                       President of various  subsidiaries  of  ReliaStar  Financial
                                       Corp.                                                       

John H. Flittie***                     Vice  Chairman,  President  and Chief  Operating  Officer of
20 Washington Ave. So.                 ReliaStar Life Insurance  Company since 1996;  President and
Minneapolis, MN  55401                 Chief  Operating  Officer of ReliaStar  Financial  Corp. and
                                       ReliaStar Life Insurance  Company since 1993; Vice Chairman,
                                       Chief Executive  Officer and President of ReliaStar  Bankers
                                       Security Life Insurance Company since 1996; Vice Chairman of
                                       ReliaStar   United  Services  Life  Insurance   Company  and
                                       ReliaStar  Bankers  Security  Life  Insurance  Company since
                                       1995;  Senior  Executive Vice President and Chief  Operating
                                       Officer of ReliaStar  Financial  Corp.  and  ReliaStar  Life
                                       Insurance  Company from 1992 to 1993;  Senior Executive Vice
                                       President and Chief Operating Officer of ReliaStar Financial
                                       Corp. from 1991 to 1992;  Executive Vice President and Chief
                                       Financial Officer of ReliaStar Financial Corp. and ReliaStar
                                       Life  Insurance  Company  from  1989 to  1991;  Director  of
                                       Community First BankShares, Inc. and Director and Officer of
                                       various subsidiaries of ReliaStar Financial Corp.           

James T. Hale*                         Senior Vice  President of Dayton  Hudson  Corporation  since
777 Nicollet Mall                      1981.                                                       
Minneapolis, MN  55402                 

Wayne R. Huneke***                     Senior Vice President, Chief Financial Officer and Treasurer
20 Washington Ave. So.                 of ReliaStar  Financial  Corp.  and ReliaStar Life Insurance
Minneapolis, MN  55401                 Company  since 1994;  Vice  President,  Treasurer  and Chief
                                       Accounting  Officer from 1990 to 1994;  Director and Officer
                                       of various subsidiaries of ReliaStar Financial Corp.        
                                       
Kennuth U. Kuk***                      Senior Vice  President  of  ReliaStar  Financial  Corp.  and
20 Washington Ave. So.                 ReliaStar Life Insurance Company since 1996; Vice President,
Minneapolis, MN  55401                 Strategic   Marketing  of  ReliaStar   Financial  Corp.  and
                                       ReliaStar Life Insurance  Company since 1996; Vice President
                                       of Investments  of ReliaStar  Financial  Corp.  from 1991 to
                                       1996;  President of Washington  Square Advisers,  Inc. since
                                       1995; Chairman of ReliaStar Mortgage Corporation since 1988;
                                       Director  of National  Commercial  Finance  Association  and
                                       Director  and Officer of various  subsidiaries  of ReliaStar
                                       Financial Corp.                                             

Richard E. Nolan*                      Senior  Counsel of Davis Polk &  Wardwell  (law firm)  since
One Chase Manhattan Plaza              1996 and Partner from 1990 to 1996.                         
New York, NY  10005                    

Fioravante G. Perrotta*                Retired 1996; Formerly Senior Partner of Rogers & Wells (law
200 Park Ave.                          firm) since 1970.                                           
New York, NY  10166                    

Robert C. Salipante***                 Senior  Vice  President  of Personal  Financial  Services of
20 Washington Ave. So.                 ReliaStar  Financial  Corp.  and  ReliaStar  Life  Insurance
Minneapolis, MN  55401                 Company since 1996;  Executive  Vice  President of ReliaStar
                                       Bankers Security Life Insurance  Company since 1996;  Senior
                                       Vice  President of  Individual  Division and  Technology  of
                                       ReliaStar  Life  Insurance  Company since 1996;  Senior Vice
                                       President of Strategic Marketing and Technology of ReliaStar
                                       Financial  Corp. and ReliaStar  Life Insurance  Company from
                                       1994 to 1996;  Senior  Vice  President  and Chief  Financial
                                       Officer of ReliaStar  Financial  Corp.  and  ReliaStar  Life
                                       Insurance   Company  from  1992  to  1994;   Executive  Vice
                                       President  of  Ameritrust  Corporation  from  1988 to  1992;
                                       Director  and Officer of various  subsidiaries  of ReliaStar
                                       Financial Corp.                                             

David J. Sloane**                      Executive  Vice  President  and Chief  Operating  Officer of 
1000 Woodbury Rd. #102                 ReliaStar  Bankers  Security  Life  Insurance  Company since 
Woodbury, NY  11797                    1990.                                                        
                                       
John G. Turner***                      Chairman and Chief Executive Officer of ReliaStar  Financial
20 Washington Ave. So.                 Corp.  and  ReliaStar  Life  Insurance  Company  since 1993;
Minneapolis, MN  55401                 Chairman of ReliaStar United Services Life Insurance Company
                                       and ReliaStar  Bankers Security Life Insurance Company since
                                       1995;  Chairman of Northern  Life  Insurance  Company  since
                                       1992;  Chairman,  President and Chief  Executive  Officer of
                                       ReliaStar  Financial  Corp.  and  ReliaStar  Life  Insurance
                                       Company in 1993;  President and Chief  Executive  Officer of
                                       ReliaStar  Financial  Corp.  and  ReliaStar  Life  Insurance
                                       Company  from 1991 to 1993;  President  and Chief  Operating
                                       Officer  of  ReliaStar  Financial  Corp.  from 1989 to 1991;
                                       President  and Chief  Operating  Officer of  ReliaStar  Life
                                       Insurance Company from 1986 to 1991; Director and Officer of
                                       various subsidiaries of ReliaStar Financial Corp.           

Charles B. Updike*                     Partner of Schoeman, Marsh & Updike (law firm) since 1976.
60 East 42nd Street                    
New York, NY  10165

Ross M. Weale*                         President   of   Waccabuc   Enterprise,   Inc.   (management
102 Brewster Ave. Rt. 6                consulting  firm) since 1996;  President and Chief Executive
Carmel, NY  10512                      Officer of Country Bank (financial institution) from 1986 to
                                       1996.                                                       

Steven W. Wishart***                   Senior  Vice  President  and  Chief  Investment  Officer  of 
20 Washington Ave. So.                 ReliaStar  Financial Corp. since 1989; Senior Vice President 
Minneapolis, MN  55401                 of ReliaStar  Life Insurance  Company since 1981;  President 
                                       and  Chief   Executive   Officer  of  ReliaStar   Investment 
                                       Research,  Inc. (formerly WSCR, Inc.) since 1996;  President 
                                       of  Washington  Square  Capital  Inc.  from  1981  to  1996; 
                                       President  of WSCR,  Inc.  from  1986 to 1996;  Director  of 
                                       National Benefit  Resources Group Services Inc. and Director 
                                       and Officer of various  subsidiaries of ReliaStar  Financial 
                                       Corp.                                                        


*     Director            
**    Officer             
***   Director and Officer

</TABLE>

The Executive  Committee of our Board of Directors consists of Directors Turner,
Flittie, Hale, Huneke, and Weale.

The Compliance  Committee of our Board of Directors consists of Directors Weale,
Carb, Hale, Nolan, Perrotta, and Updike.

     29.  FURNISH AS AT LATEST  PRACTICABLE DATE THE FOLLOWING  INFORMATION WITH
          RESPECT TO EACH COMPANY WHICH DIRECTLY OR INDIRECTLY OWNS, CONTROLS OR
          HOLDS  WITH  POWER  TO  VOTE  5% OR  MORE  OF THE  OUTSTANDING  VOTING
          SECURITIES OF THE DEPOSITOR.

          The Depositor is indirectly wholly owned by ReliaStar  Financial Corp.
          ("RFC"),  as  follows:  RFC  owns  all the  stock  of  ReliaStar  Life
          Insurance  Company,  which  owns  all the  stock of  ReliaStar  United
          Services Life Insurance  Company,  which in turn owns all the stock of
          the Depositor.  FMR Corp., 82 Devonshire Street, Boston, MA 02109 owns
          9.31% of the outstanding voting securities of RFC (3,740,449 shares of
          Common Stock) and Wilmington Trust Company,  1100 North Market Street,
          Wilmington, DE 19890 owns 6.6% of the outstanding voting securities of
          RFC (2,652,257 shares of Common Stock).

     30.  FURNISH AS AT LATEST  PRACTICABLE DATE THE FOLLOWING  INFORMATION WITH
          RESPECT TO ANY PERSON, OTHER THAN THOSE COVERED BY ITEMS 28, 29 AND 42
          WHO DIRECTLY OR INDIRECTLY CONTROLS THE DEPOSITOR.

          None.

          COMPENSATION OF OFFICERS AND DIRECTORS OF DEPOSITOR

          COMPENSATION OF OFFICERS OF DEPOSITOR

     31.  FURNISH THE FOLLOWING INFORMATION WITH RESPECT TO THE REMUNERATION FOR
          SERVICES PAID BY THE DEPOSITOR  DURING THE LAST FISCAL YEAR COVERED BY
          FINANCIAL STATEMENTS FILED HEREWITH.

          (a)  DIRECTLY TO EACH OF THE  OFFICERS  OR  PARTNERS OF THE  DEPOSITOR
               DIRECTLY RECEIVING THE THREE HIGHEST AMOUNTS OF REMUNERATION;

          (b)  DIRECTLY TO ALL OFFICERS OR PARTNERS OF THE  DEPOSITOR AS A GROUP
               EXCLUSIVE OF PERSONS WHOSE  REMUNERATION  IS INCLUDED  UNDER ITEM
               31(A),  STATING  SEPARATELY  THE  AGGREGATE  AMOUNT  PAID  BY THE
               DEPOSITOR  ITSELF  AND  THE  AGGREGATE  AMOUNT  PAID  BY ALL  THE
               SUBSIDIARIES;

          (c)  INDIRECTLY  OR THROUGH  SUBSIDIARIES  TO EACH OF THE  OFFICERS OR
               PARTNERS OF THE depositor.

               No officer has been paid any  remuneration  by RBSL for  services
               with respect to the Variable Account.

          COMPENSATION OF DIRECTORS

     32.  FURNISH THE FOLLOWING INFORMATION WITH RESPECT TO THE REMUNERATION FOR
          SERVICES,  EXCLUSIVE OF  REMUNERATION  REPORTED UNDER ITEM 31, PAID BY
          THE  DEPOSITOR  DURING  THE LAST  FISCAL  YEAR  COVERED  BY  FINANCIAL
          STATEMENTS FILED HEREWITH;

          (a)  THE AGGREGATE DIRECT REMUNERATION TO DIRECTORS;

          (b)  INDIRECTLY OR THROUGH SUBSIDIARIES TO DIRECTORS.

               No director has been paid any  remuneration  by RBSL for services
               with respect to the Variable Account.

          COMPENSATION TO EMPLOYEES

     33.  (a)  FURNISH THE  FOLLOWING INFORMATION  WITH RESPECT TO THE AGGREGATE
               AMOUNT OF REMUNERATION  FOR SERVICES OF ALL EMPLOYEES OF THE 
               DEPOSITOR (EXCLUSIVE OF PERSONS WHOSE REMUNERATION IS REPORTED IN
               ITEMS 31 AND 32) WHO  RECEIVED REMUNERATION IN EXCESS OF $10,000
               DURING THE LAST FISCAL YEAR COVERED BY FINANCIAL STATEMENTS FILED
               HEREWITH FROM THE DEPOSITOR AND ANY OF ITS SUBSIDIARIES.

               No such  person  has  been  paid  any  remuneration  by RBSL  for
               services with respect to the Variable Account.

          (b)  FURNISH   THE   FOLLOWING   INFORMATION   WITH   RESPECT  TO  THE
               REMUNERATION  FOR SERVICES PAID  DIRECTLY  DURING THE LAST FISCAL
               YEAR  COVERED  BY  FINANCIAL  STATEMENTS  FILED  HEREWITH  TO THE
               FOLLOWING CLASSES OF PERSONS  (EXCLUSIVE OF THOSE PERSONS COVERED
               BY ITEM 33(A):  (1) SALES  MANAGERS,  BRANCH  MANAGERS,  DISTRICT
               MANAGERS AND OTHER PERSONS  SUPERVISING  THE SALE OF REGISTRANT'S
               SECURITIES;  (2)  SALESMEN,  SALES AGENTS,  CANVASSERS  AND OTHER
               PERSONS MAKING SOLICITATIONS BUT NOT IN SUPERVISORY CAPACITY; (3)
               ADMINISTRATIVE  AND  CLERICAL  EMPLOYEES;  AND (4)  OTHERS.  IF A
               PERSON IS EMPLOYED IN MORE THAN ONE CAPACITY,  CLASSIFY ACCORDING
               TO PREDOMINANT TYPE OF WORK.

               No such  person  has  been  paid  any  remuneration  by RBSL  for
               services with respect to the Variable Account.

          COMPENSATION TO OTHER PERSONS

     34.  FURNISH THE FOLLOWING INFORMATION WITH RESPECT TO THE AGGREGATE AMOUNT
          OF  COMPENSATION  FOR SERVICES  PAID ANY PERSON  (EXCLUSIVE OF PERSONS
          WHOSE  REMUNERATION  IS  REPORTED  IN  ITEMS  31,  32 AND  33),  WHOSE
          AGGREGATE  COMPENSATION  IN  CONNECTION  WITH  SERVICES  RENDERED WITH
          RESPECT TO THE TRUST IN ALL  CAPACITIES  EXCEEDED  $10,000  DURING THE
          LAST FISCAL YEAR COVERED BY FINANCIAL  STATEMENTS  FILED HEREWITH FROM
          THE DEPOSITOR AND ANY OF ITS SUBSIDIARIES.

          No such person has been paid remuneration in excess of $10,000 by RBSL
          for services with respect to the Variable Account.

IV.  DISTRIBUTION AND REDEMPTION OF SECURITIES

          DISTRIBUTION OF SECURITIES

     35.  FURNISH  THE  NAMES  OF THE  STATES  IN  WHICH  SALES  OF THE  TRUST'S
          SECURITIES (A) ARE CURRENTLY BEING MADE, (B) ARE PRESENTLY PROPOSED TO
          BE MADE,  AND (C) HAVE BEEN  DISCONTINUED,  INDICATING BY  APPROPRIATE
          LETTER THE STATUS WITH RESPECT TO EACH STATE.

          No sales of the Policies are currently  being made nor have sales been
          discontinued in any state. It is presently  proposed that the Policies
          will be sold in all states where RBSL is  authorized  to sell variable
          life insurance.

     36.  IF SALES OF THE TRUST'S  SECURITIES  HAVE AT ANY TIME SINCE JANUARY 1,
          1936 BEEN SUSPENDED FOR MORE THAN A MONTH DESCRIBE BRIEFLY THE REASONS
          FOR SUCH SUSPENSION.

          Sales of the Policies have never been suspended.

     37.  (a)  FURNISH THE FOLLOWING  INFORMATION  WITH RESPECT TO EACH INSTANCE
               WHERE SUBSEQUENT TO JANUARY 1, 1937, ANY FEDERAL OR STATE 
               GOVERNMENTAL OFFICER, AGENCY OR REGULATORY BODY DENIED AUTHORITY 
               TO DISTRIBUTE SECURITIES OF THE TRUST, EXCLUDING A DENIAL  WHICH 
               WAS MERELY A PROCEDURAL STEP PRIOR TO ANY DETERMINATION BY SUCH 
               OFFICER, ETC. AND WHICH DENIAL WAS SUBSEQUENTLY RESCINDED.

               (1)  NAME OF OFFICER, AGENCY OR BODY.

               (2)  DATE OF DENIAL.

               (3)  BRIEF STATEMENT OF REASON GIVEN FOR DENIAL.

               Authority to distribute the Policies has never been denied.

          (b)  FURNISH THE  FOLLOWING  INFORMATION  WITH REGARD TO EACH INSTANCE
               WHERE, SUBSEQUENT TO JANUARY 1, 1937, THE AUTHORITY TO DISTRIBUTE
               SECURITIES  OF THE TRUST HAS BEEN REVOKED BY ANY FEDERAL OR STATE
               GOVERNMENTAL OFFICER, AGENCY OR REGULATORY BODY.

               (1)  NAME OF OFFICER, AGENCY OR BODY.

               (2)  DATE OF REVOCATION.

               (3)  BRIEF STATEMENT OF REASON GIVEN FOR REVOCATION.

               Authority to distribute the Policies has never been revoked.

     38.  (a)  FURNISH A GENERAL  DESCRIPTION  OF THE METHOD OF  DISTRIBUTION OF
               SECURITIES OF THE TRUST.

               RBSL intends to sell the Policies in all  jurisdictions  where it
               is  licensed.  The  Policies  will be sold by licensed  insurance
               agents who are also registered  representatives of broker-dealers
               registered  under  the  Securities  Exchange  Act of 1934 who are
               members of the National  Association of Securities Dealers,  Inc.
               The Policies will be distributed by the Distributor,  which is an
               affiliate of RBSL.

          (b)  STATE THE SUBSTANCE OF ANY CURRENT SELLING AGREEMENT BETWEEN EACH
               PRINCIPAL UNDERWRITER AND THE TRUST OR THE DEPOSITOR, INCLUDING A
               STATEMENT  AS TO  THE  INCEPTION  AND  TERMINATION  DATES  OF THE
               AGREEMENT,  ANY  RENEWAL  AND  TERMINATION  PROVISIONS,  AND  ANY
               ASSIGNMENT PROVISIONS.

               The   Distributor  and  RBSL  intend  to  enter  into  a  General
               Distributor Agreement, a copy of the form of which is filed as an
               exhibit hereto,  the terms of which  (including those relating to
               renewal,  termination and assignment) are incorporated  herein by
               reference.

          (c)  STATE THE SUBSTANCE OF ANY CURRENT  AGREEMENTS OR ARRANGEMENTS OF
               EACH PRINCIPAL UNDERWRITER WITH DEALERS,  AGENTS,  SALESMEN, ETC.
               WITH  RESPECT  TO   COMMISSIONS   AND   OVERRIDING   COMMISSIONS,
               TERRITORIES,  FRANCHISES,  QUALIFICATIONS AND REVOCATIONS. IF THE
               TRUST  IS THE  ISSUER  OF  PERIODIC  PAYMENT  PLAN  CERTIFICATES,
               FURNISH  SCHEDULES OF COMMISSIONS AND THE BASES THEREOF.  IN LIEU
               OF  A  STATEMENT  CONCERNING   SCHEDULES  OF  COMMISSIONS,   SUCH
               SCHEDULES OF COMMISSIONS MAY BE FILED AS EXHIBIT A(3)(C).

               There is no current agreements or arrangements of the Distributor
               with dealers, agents, salesmen, etc., relating to the Policies.

               INFORMATION CONCERNING PRINCIPAL UNDERWRITER

     39.  (a)  STATE THE FORM OF  ORGANIZATION OF EACH PRINCIPAL  UNDERWRITER OF
               SECURITIES  OF THE  TRUST,  THE NAME OF THE  STATE OR OTHER 
               SOVEREIGN POWER UNDER THE LAWS OF WHICH EACH  UNDERWRITER  WAS 
               ORGANIZED AND THE DATE OF ORGANIZATION.

               The Distributor is a corporation  organized under the laws of the
               State of Minnesota on April 26, 1968.

          (b)  STATE WHETHER ANY PRINCIPAL  UNDERWRITER  CURRENTLY  DISTRIBUTING
               SECURITIES  OF THE TRUST IS A MEMBER OF THE NATIONAL  ASSOCIATION
               OF SECURITIES DEALERS, INC..

               The  Distributor,  which will serve as principal  underwriter for
               the  Policies,  is  a  member  of  the  National  Association  of
               Securities Dealers, Inc.

     40.  (a)  FURNISH  THE  FOLLOWING  INFORMATION  WITH  RESPECT  TO ALL  FEES
               RECEIVED BY EACH  PRINCIPAL  UNDERWRITER OF THE TRUST FROM THE 
               SALE OF SECURITIES OF THE TRUST AND  ANY  OTHER  FUNCTIONS  IN  
               CONNECTION THEREWITH  EXERCISED BY SUCH UNDERWRITER IN SUCH 
               CAPACITY OR OTHERWISE DURING THE PERIOD COVERED BY THE FINANCIAL
               STATEMENTS FILED HEREWITH.

               The Distributor has not yet received any such fees.

          (b)  FURNISH THE FOLLOWING  INFORMATION WITH RESPECT TO ANY FEE OR ANY
               PARTICIPATION IN FEES RECEIVED BY EACH PRINCIPAL UNDERWRITER FROM
               ANY UNDERLYING  INVESTMENT  COMPANY OR ANY  AFFILIATED  PERSON OR
               INVESTMENT ADVISER OF SUCH COMPANY:

               (1)  THE NATURE OF SUCH FEE OR PARTICIPATION.

               (2)  THE NAME OF THE PERSON MAKING PAYMENT.

               (3)  THE NATURE OF THE  SERVICES  RENDERED IN  CONSIDERATION  FOR
                    SUCH FEE OR PARTICIPATION.

               (4)  THE AGGREGATE  AMOUNT  RECEIVED  DURING THE LAST FISCAL YEAR
                    COVERED BY THE FINANCIAL STATEMENTS FILED HEREWITH.

               None.

     41.  (a)  DESCRIBE THE GENERAL CHARACTER OF THE BUSINESS ENGAGED IN BY EACH
               PRINCIPAL UNDERWRITER,  INCLUDING A STATEMENT AS TO ANY BUSINESS
               OTHER THAN THE DISTRIBUTION OF SECURITIES OF THE TRUST. IF A  
               PRINCIPAL UNDERWRITER ACTS OR HAS ACTED IN ANY CAPACITY  WITH  
               RESPECT TO ANY INVESTMENT COMPANY OR COMPANIES OTHER THAN THE 
               TRUST, STATE THE NAME OR NAMES OF SUCH COMPANY OR COMPANIES, 
               THEIR RELATIONSHIP, IF ANY, TO THE TRUST AND THE NATURE OF SUCH  
               ACTIVITIES. IF A PRINCIPAL UNDERWRITER HAS CEASED TO ACT IN SUCH 
               NAMED CAPACITY, STATE THE DATE OF AND CIRCUMSTANCES SURROUNDING 
               SUCH CESSATION.

               The Distributor is a securities broker-dealer registered with the
               SEC and is a member of the  National  Association  of  Securities
               Dealers,  Inc.  It is  primarily  a mutual  funds  dealer and has
               dealer  agreements  under which it markets shares of more than 50
               mutual  funds.  It also markets  limited  partnerships  and other
               tax-sheltered  or  deferred  investments,  and  acts  as  general
               distributor  (principal  underwriter)  for  variable  annuity and
               variable life products issued by RBSL.

          (b)  FURNISH AS AT LATEST  PRACTICABLE DATE THE ADDRESS OF EACH BRANCH
               OFFICE OF EACH PRINCIPAL UNDERWRITER CURRENTLY SELLING SECURITIES
               OF THE TRUST AND  FURNISH THE NAME AND  RESIDENCE  ADDRESS OF THE
               PERSON IN CHARGE OF SUCH OFFICE.

               Not applicable.

          (c)  FURNISH  THE  NUMBER OF  INDIVIDUAL  SALESMEN  OF EACH  PRINCIPAL
               UNDERWRITER  THROUGH WHOM ANY OF THE SECURITIES OF THE TRUST WERE
               DISTRIBUTED  FOR THE LAST FISCAL YEAR OF THE TRUST COVERED BY THE
               FINANCIAL  STATEMENTS  FILED  HEREWITH AND FURNISH THE  AGGREGATE
               AMOUNT OF COMPENSATION RECEIVED BY SUCH SALESMEN IN SUCH YEAR.

               Sales of the Policies have not yet commenced.

     42.  FURNISH AS AT LATEST  PRACTICABLE DATE THE FOLLOWING  INFORMATION WITH
          RESPECT  TO  EACH   PRINCIPAL   UNDERWRITER   CURRENTLY   DISTRIBUTING
          SECURITIES  OF THE TRUST  AND WITH  RESPECT  TO EACH OF THE  OFFICERS,
          DIRECTORS OR PARTNERS OF SUCH UNDERWRITER.

          No Policies have yet been issued by the Variable Account.

     43.  FURNISH,  FOR THE LAST FISCAL YEAR COVERED BY THE FINANCIAL STATEMENTS
          FILED HEREWITH,  THE AMOUNT OF BROKERAGE  COMMISSIONS  RECEIVED BY ANY
          PRINCIPAL  UNDERWRITER  WHO  IS  A  MEMBER  OF A  NATIONAL  SECURITIES
          EXCHANGE AND WHO IS CURRENTLY DISTRIBUTING THE SECURITIES OF THE TRUST
          OR EFFECTING TRANSACTIONS FOR THE TRUST IN THE PORTFOLIO SECURITIES OF
          THE TRUST.

          Not applicable.

          OFFERING PRICE OR ACQUISITION VALUATION OF SECURITIES OF THE TRUST

     44.  (a)  FURNISH THE  FOLLOWING INFORMATION  WITH RESPECT TO THE METHOD OF
               VALUATION  USED BY THE TRUST FOR PURPOSE OF  DETERMINING  THE 
               OFFERING PRICE TO THE PUBLIC OF SECURITIES ISSUED BY THE TRUST OR
               THE VALUATION OF SHARES OR INTERESTS IN THE UNDERLYING SECURITIES
               ACQUIRED BY THE HOLDER OF A PERIODIC PAYMENT PLAN CERTIFICATE.

               (1)  THE  SOURCE OF  QUOTATIONS  USED TO  DETERMINE  THE VALUE OF
                    PORTFOLIO SECURITIES.

                    Fund  shares are valued at net asset  value as  supplied  to
                    RBSL by the Funds or their agents.

               (2)  WHETHER OPENING,  CLOSING,  BID, ASKED OR ANY OTHER PRICE IS
                    USED.

                    See the answers to Items 44(a)(1) and 16.

               (3)  WHETHER  PRICE  IS AS OF THE DAY OF SALE OR AS OF ANY  OTHER
                    TIME.

                    See the answer to Item 16.

               (4)  A BRIEF  DESCRIPTION  OF THE METHODS USED BY REGISTRANT  FOR
                    DETERMINING  OTHER ASSETS AND LIABILITIES  INCLUDING ACCRUAL
                    FOR  EXPENSES  AND  TAXES  (INCLUDING  TAXES  ON  UNREALIZED
                    APPRECIATION).

                    The  Variable  Account's  assets  and  liabilities  (such as
                    charges   against  the  Variable   Account)  are  valued  in
                    accordance with generally accepted accounting  principles on
                    an  accrual  basis.  Since RBSL does not expect to incur any
                    substantial  federal income tax  liabilities on the earnings
                    or the capital gains  attributable  to the Variable  Account
                    for the immediate  future,  RBSL does not intend to create a
                    reserve  for  its  federal   income   taxes  in   connection
                    therewith.

               (5)  OTHER ITEMS WHICH  REGISTRANT ADDS TO THE NET ASSET VALUE IN
                    COMPUTING OFFERING PRICE OF ITS SECURITIES.

                    Not applicable.

               (6)  WHETHER ADJUSTMENTS ARE MADE FOR FRACTIONS:

                    (i) BEFORE ADDING DISTRIBUTOR'S COMPENSATION (LOAD); AND

                    (ii) AFTER ADDING DISTRIBUTOR'S COMPENSATION (LOAD)

                    Not applicable because the Variable Account does not compute
                    per-unit values and sales loads in the manner presupposed by
                    this Item and Item 44(b).  Appropriate  adjustments  will be
                    made for fractions in all computations.

          (b)  FURNISH  A  SPECIMEN  SCHEDULE  SHOWING  THE  COMPONENTS  OF  THE
               OFFERING  PRICE  OF  THE  TRUST'S  SECURITIES  AS AT  THE  LATEST
               PRACTICABLE DATE.

               The Policies have not yet been offered for sale.

          (c)  IF THERE IS ANY  VARIATION IN THE  OFFERING  PRICE OF THE TRUST'S
               SECURITIES  TO ANY  PERSON  OR  CLASSES  OF  PERSONS  OTHER  THAN
               UNDERWRITERS,  STATE THE NATURE AND AMOUNT OF SUCH  VARIATION AND
               INDICATE  THE PERSON OR CLASSES OF PERSONS TO WHOM SUCH  OFFERING
               IS MADE.

               RBSL  does not  require a premium  payment  of a fixed  amount at
               fixed intervals for a specified time period.  A Policy owner may,
               subject to the limitations set forth in Item 10(i),  pay premiums
               at any frequency in any amount. Nonetheless, if the Death Benefit
               Guarantee  is  not in  effect  Policy  owners  will  need  to pay
               sufficient  premiums to maintain adequate Cash Surrender Value to
               pay the Monthly Deduction,  including the cost of insurance.  The
               cost of insurance  will vary,  depending  upon the insured's sex,
               attained  age,  and  Rate  Class.  In  addition,  there  will  be
               additional  charges if optional  insurance  benefits are elected.
               Thus, for the Policy to remain in force, a Policy owner will need
               to take the cost of  insurance,  as well as other factors such as
               investment  performance,  into  consideration  in determining the
               amount and frequency of premium payments.

     45.  FURNISH THE FOLLOWING  INFORMATION  WITH RESPECT TO ANY  SUSPENSION OF
          THE REDEMPTION RIGHTS OF THE SECURITIES ISSUED BY THE TRUST DURING THE
          THREE FISCAL YEARS COVERED BY THE FINANCIAL STATEMENTS FILED HEREWITH:

          (a)  BY WHOSE ACTION REDEMPTION RIGHTS WERE SUSPENDED.

          (b)  THE NUMBER OF DAYS' NOTICE GIVEN TO SECURITY HOLDERS.

          (c)  REASON FOR SUSPENSION.

          (d)  PERIOD DURING WHICH SUSPENSION WAS IN EFFECT.

          There has been no suspension of the right to redeem the Policies.

          REDEMPTION VALUATION OF SECURITIES OF THE TRUST

     46.  (a)  FURNISH THE  FOLLOWING INFORMATION  WITH RESPECT TO THE METHOD OF
               DETERMINING  THE  REDEMPTION  OR  WITHDRAWAL  VALUATION OF  
               SECURITIES ISSUED BY THE TRUST:

               (1)  THE  SOURCE OF  QUOTATIONS  USED TO  DETERMINE  THE VALUE OF
                    PORTFOLIO SECURITIES.

                    See the answer to Item 44(a)(2).

               (2)  WHETHER OPENING,  CLOSING,  BID, ASKED OR ANY OTHER PRICE IS
                    USED.

                    See the answer to Item 44(a)(2).

               (3)  WHETHER  PRICE  IS AS OF THE DAY OF SALE OR AS OF ANY  OTHER
                    TIME.

                    As of the day a request for surrender is received.

               (4)  A BRIEF  DESCRIPTION  OF THE METHODS USED BY REGISTRANT  FOR
                    DETERMINING  OTHER ASSETS AND LIABILITIES  INCLUDING ACCRUAL
                    FOR  EXPENSES  AND  TAXES  (INCLUDING  TAXES  ON  UNREALIZED
                    APPRECIATION).

                    See the answers to Items 44(a)(4) and 18(c).

               (5)  OTHER  ITEMS  WHICH  REGISTRANT  DEDUCTS  FROM THE NET ASSET
                    VALUE IN COMPUTING REDEMPTION VALUE OF ITS SECURITIES.

                    See the answer to Items 10(c) and 13(a).

               (6)  (A)  WHETHER ADJUSTMENTS ARE MADE FOR FRACTIONS.

                         Not applicable.

                    (B)  FURNISH A SPECIMEN  SCHEDULE  SHOWING THE COMPONENTS OF
                         THE  REDEMPTION  PRICE TO THE  HOLDERS  OF THE  TRUST'S
                         SECURITIES AS AT THE LATEST PRACTICABLE DATE.

                         The Policies have not yet been offered for sale.

          PURCHASE AND SALE OF INTERESTS IN  UNDERLYING  SECURITIES  FROM AND TO
          SECURITY HOLDERS

     47.  FURNISH  A  STATEMENT  AS  TO  THE  PROCEDURE   WITH  RESPECT  TO  THE
          MAINTENANCE OF A POSITION IN THE UNDERLYING SECURITIES OR INTERESTS IN
          THE  UNDERLYING  SECURITIES,  THE EXTENT AND  NATURE  THEREOF  AND THE
          PERSON WHO MAINTAINS  SUCH A POSITION.  INCLUDE A  DESCRIPTION  OF THE
          PROCEDURE  WITH RESPECT TO THE PURCHASE OF  UNDERLYING  SECURITIES  OR
          INTERESTS  IN THE  UNDERLYING  SECURITIES  FROM  SECURITY  HOLDERS WHO
          EXERCISE  REDEMPTION  OR  WITHDRAWAL  RIGHTS  AND  THE  SALE  OF  SUCH
          UNDERLYING  SECURITIES AND INTERESTS IN THE  UNDERLYING  SECURITIES TO
          OTHER SECURITY HOLDERS.  STATE WHETHER THE METHOD OF VALUATION OF SUCH
          UNDERLYING  SECURITIES OR INTERESTS IN UNDERLYING  SECURITIES  DIFFERS
          FROM  THAT SET  FORTH IN ITEMS 44 AND 46.  IF ANY ITEM OF  EXPENDITURE
          INCLUDED  IN THE  DETERMINATION  OF THE  VALUATION  IS NOT OR MAY  NOT
          ACTUALLY BE INSURED OR  EXPENDED,  EXPLAIN THE NATURE OF SUCH ITEM AND
          WHO MAY BENEFIT FROM THE  TRANSACTION,  THE EXTENT AND NATURE  THEREOF
          AND THE PERSON WHO MAINTAINS SUCH A POSITION. INCLUDE A DESCRIPTION OF
          THE PROCEDURE WITH RESPECT TO THE PURCHASE OF UNDERLYING SECURITIES OR
          INTERESTS  IN THE  UNDERLYING  SECURITIES  FROM  SECURITY  HOLDERS WHO
          EXERCISE  REDEMPTION  OR  WITHDRAWAL  RIGHTS  AND  THE  SALE  OF  SUCH
          UNDERLYING  SECURITIES AND INTERESTS IN THE  UNDERLYING  SECURITIES TO
          OTHER SECURITY HOLDERS.  STATE WHETHER THE METHOD OF VALUATION OF SUCH
          UNDERLYING  SECURITIES OR INTERESTS IN UNDERLYING  SECURITIES  DIFFERS
          FROM  THAT SET  FORTH IN ITEMS 44 AND 46.  IF ANY ITEM OF  EXPENDITURE
          INCLUDED  IN THE  DETERMINATION  OF THE  VALUATION  IS NOT OR MAY  NOT
          ACTUALLY BE INSURED OR  EXPENDED,  EXPLAIN THE NATURE OF SUCH ITEM AND
          WHO MAY BENEFIT FROM THE TRANSACTION.

          RBSL will  maintain a  position  in the Funds by (a)  purchasing  Fund
          shares  at net  asset  value  in  connection  with  the  net  premiums
          allocated to the Variable Account in accordance with instructions from
          Policy owners and (b) redeeming Fund shares at net asset value for the
          purpose  of  meeting  Policy  obligations.  See the answer to Item 16.
          There is no procedure  for the purchase of  underlying  securities  or
          interests therein from Policy owners who exercise surrender rights.

          See the  answer to Item 27 with  respect to  certain  other  contracts
          issued by RBSL with benefits that may vary depending on the investment
          results of certain of the Funds.

V.   INFORMATION CONCERNING THE TRUSTEE OR CUSTODIAN

     48.  FURNISH THE FOLLOWING  INFORMATION  AS TO SUCH TRUSTEE OR CUSTODIAN OF
          THE TRUST.

          (a)  NAME AND PRINCIPAL BUSINESS ADDRESS

          (b)  FORM OF ORGANIZATION

          (c)  STATE OR  OTHER  SOVEREIGN  POWER  UNDER  THE  LAWS OF WHICH  THE
               TRUSTEE OR CUSTODIAN WAS ORGANIZED

          (d)  NAME OF GOVERNMENTAL SUPERVISING OR EXAMINING AUTHORITY

          See the answer to Item 2 for the principal  business  address of RBSL.
          RBSL is a stock life insurance company organized under the laws of the
          State of New  York.  It is  subject  to  regulation  by the  Insurance
          Department of the State of New York. The books and records of RBSL are
          subject to review and  examination by that Department at all times and
          a full  examination  of its  operations  is  conducted by the National
          Association of Insurance Commissioners periodically. In addition, RBSL
          is  subject  to the  insurance  laws  and  regulations  of  the  other
          jurisdictions in which it is licensed to operate.

     49.  STATE THE BASIS FOR  PAYMENT  OF FEES OR  EXPENSES  OF THE  TRUSTEE OR
          CUSTODIAN  FOR  SERVICES  RENDERED  WITH  RESPECT TO THE TRUST AND ITS
          SECURITIES, AND THE AGGREGATE AMOUNT THEREOF FOR THE LAST FISCAL YEAR.
          INDICATE  THE  PERSON  PAYING  SUCH FEES OR  EXPENSES.  IF ANY FEES OR
          EXPENSES ARE PREPAID, STATE THE UNEARNED AMOUNT.

          Not applicable.

     50.  STATE  WHETHER THE TRUSTEE OR CUSTODIAN OR ANY OTHER PERSON HAS OR MAY
          CREATE  A LIEN  ON THE  ASSETS  OF THE  TRUST,  AND IF SO,  GIVE  FULL
          PARTICULARS,   OUTLINING  THE  SUBSTANCE  OF  THE  PROVISIONS  OF  ANY
          INDENTURE OR AGREEMENT WITH RESPECT THERETO.

          There is no trustee.  Neither RBSL as custodian, nor any other person,
          has or may  create a lien on the  assets of the  trust.  The  Policies
          provide in  implementation of New York law that assets of the Variable
          Account  equal to the reserves and other  liabilities  of the Variable
          Account may not be used to satisfy any obligations  arising out of any
          other business RBSL may conduct.

VI.  INFORMATION CONCERNING INSURANCE OF HOLDERS OF SECURITIES

     51.  FURNISH THE FOLLOWING INFORMATION WITH RESPECT TO INSURANCE OF HOLDERS
          OF SECURITIES.

          (a)  THE NAME AND ADDRESS OF THE INSURANCE COMPANY

               ReliaStar Bankers Security Life Insurance Company
               1000 Woodbury Road, Woodbury
               Long Island, New York 11797

          (b)  THE TYPES OF POLICIES AND WHETHER INDIVIDUAL OR GROUP POLICIES

               Flexible premium variable life insurance policies

          (c)  THE TYPES OF RISKS INSURED AND EXCLUDED

               The Policies are issued to provide  protection  against  economic
               loss when the insured dies.  The Policy  provides a Death Benefit
               which is payable to the named  beneficiary  whenever  the insured
               dies.  See the answer to Item 10(i) for a description  of how the
               amount of the Death Benefit payable is determined.

               RBSL  assumes  the risk that the  deductions  made for  mortality
               risks will prove inadequate to cover actual mortality costs. RBSL
               also  assumes  the  risk  that  deductions  for  expenses  may be
               inadequate.

          (d)  THE COVERAGE OF THE POLICIES

               See the answers to Items 10(i) and 51(c).

          (e)  THE  BENEFICIARIES  OF SUCH  POLICIES  AND THE USES TO WHICH  THE
               PROCEEDS OF POLICIES MUST BE PUT

               A  beneficiary  is any person named on RBSL's  records to receive
               insurance  proceeds after the insured dies.  The applicant  names
               the  beneficiary  when  applying  for  a  Policy.  There  may  be
               different  classes  of  beneficiaries,  which  set the  order  of
               payment. There may be more than one beneficiary in a class.

               The beneficiary  may be changed during the insured's  lifetime by
               written  notice to RBSL.  If no  beneficiary  is living  when the
               insured dies, the death benefit will be paid to the Policy owner,
               if living, otherwise to the insured's estate.

               There  is no  restriction  on  the  use  of  payments  under  the
               Policies.

          (f)  THE TERMS AND MANNER OF CANCELLATION AND OF REINSTATEMENT

               See the answer to Item 10(e).

          (g)  THE METHOD OF  DETERMINING  THE AMOUNT OF  PREMIUMS TO BE PAID BY
               HOLDERS OF SECURITIES

               See the  answers  to Items  13(a)  and  13(d)  for the  amount of
               charges imposed. See the answers to Items 10(c), f10(i) and 44(c)
               for the manner in which the premium is determined.

          (h)  THE AMOUNT OF AGGREGATE  PREMIUMS PAID TO THE  INSURANCE  COMPANY
               DURING THE LAST FISCAL YEAR

               Sale of the Policies has not yet commenced.

          (i)  WHETHER ANY PERSON OTHER THAN THE INSURANCE  COMPANY RECEIVES ANY
               PART OF SUCH  PREMIUMS,  THE  NAME OF EACH  SUCH  PERSON  AND THE
               AMOUNTS  INVOLVED,  AND  THE  NATURE  OF  THE  SERVICES  RENDERED
               THEREFOR.

               No  person  other  than  RBSL  receives  any part of the  amounts
               deducted for assumption of mortality and expense risks.

          (j)  THE SUBSTANCE OF ANY OTHER  MATERIAL  PROVISIONS OF ANY INDENTURE
               OR AGREEMENT OF THE TRUST RELATING TO INSURANCE.

               None.

VII. POLICY OF REGISTRANT

     52.  (a)  FURNISH THE  SUBSTANCE  OF THE  PROVISIONS  OF ANY  INDENTURE  OR
               AGREEMENT WITH RESPECT TO THE CONDITIONS  UPON WHICH AND THE 
               METHOD OF SELECTION  BY WHICH  PARTICULAR PORTFOLIO  SECURITIES
               MUST OR MAY BE ELIMINATED FROM THE ASSETS OF THE TRUST OR MUST OR
               MAY BE REPLACED BY OTHER PORTFOLIO  SECURITIES.  IF AN INVESTMENT
               ADVISER OR OTHER PERSON IS TO BE EMPLOYED IN CONNECTION WITH SUCH
               SELECTION, ELIMINATION OR SUBSTITUTION, STATE THE  NAME  OF SUCH 
               PERSON, THE NATURE OF ANY AFFILIATION TO THE DEPOSITOR, TRUSTEE 
               OR CUSTODIAN, AND ANY PRINCIPAL UNDERWRITER, AND THE AMOUNT OF  
               REMUNERATION TO BE RECEIVED FOR SUCH SERVICES.  IF ANY PARTICULAR
               PERSON IS NOT DESIGNATED IN THE INDENTURE OR AGREEMENT, DESCRIBE
               BRIEFLY THE METHOD OF SELECTION OF SUCH PERSON.

               See the answers to Items 10(g) and 10(h).

          (b)  FURNISH  INFORMATION WITH RESPECT TO EACH  TRANSACTION  INVOLVING
               THE  ELIMINATION  OF ANY  UNDERLYING  SECURITY  DURING THE PERIOD
               COVERED BY THE FINANCIAL STATEMENTS FILED HEREWITH.

               No eliminations of any underlying securities have yet been made.

          (c)  DESCRIBE THE POLICY OF THE TRUST WITH RESPECT TO THE SUBSTITUTION
               AND  ELIMINATION OF THE  UNDERLYING  SECURITIES OF THE TRUST WITH
               RESPECT TO:

               (1)  THE GROUNDS FOR ELIMINATION AND SUBSTITUTION;

               (2)  THE TYPE OF  SECURITIES  WHICH  MAY BE  SUBSTITUTED  FOR ANY
                    UNDERLYING SECURITY;

               (3)  WHETHER  THE  ACQUISITION  OF SUCH  SUBSTITUTED  SECURITY OR
                    SECURITIES WOULD CONSTITUTE THE  CONCENTRATION OF INVESTMENT
                    IN A  PARTICULAR  INDUSTRY OR GROUP OF  INDUSTRIES  OR WOULD
                    CONFIRM  TO A POLICY OF  CONCENTRATION  OF  INVESTMENT  IN A
                    PARTICULAR INDUSTRY OR GROUP OF INDUSTRIES;

               (4)  WHETHER SUCH SUBSTITUTED SECURITIES MAY BE THE SECURITIES OF
                    ANOTHER INVESTMENT COMPANY; AND

               (5)  THE  SUBSTANCE  OF  THE   PROVISIONS  OF  ANY  INDENTURE  OR
                    AGREEMENT  WHICH  AUTHORIZE  OR  RESTRICT  THE POLICY OF THE
                    REGISTRANT IN THIS REGARD.

               See the answers to Items 10(g) and 10(h).

          (d)  FURNISH  A  DESCRIPTION  OF ANY  POLICY  (EXCLUSIVE  OF  POLICIES
               COVERED BY  PARAGRAPHS  (A) AND (B) HEREIN) OF THE TRUST WHICH IS
               DEEMED A MATTER OF FUNDAMENTAL  POLICY AND WHICH IS ELECTED TO BE
               TREATED AS SUCH.

               None.

               REGULATED INVESTMENT COMPANY

     53.  (a)  STATE THE TAXABLE STATUS OF THE TRUST.

               The variable  Account is  segregated  asset account and, as such,
               any tax  attributable to the Variable  Account is taxed as a part
               of  RBSL.   However,  it  accounts  separately  for  its  income,
               exclusion,  deduction,  assets, reserves and other liabilities. A
               diversified  segregated  asset  account  will not be taxed on the
               bulk of its  earnings  and gains since its basis in each asset in
               the  account  is  increased  by any  appreciation  in  value  and
               decreased by any depreciation in value.  (To be diversified,  the
               Variable   Account   must   meet   the   diversified   investment
               requirements  imposed by Section 817 of the Internal Revenue code
               of 1986 relating to Regulated Investment  Companies,  and no more
               than 55% of the value of the total assets of the Variable Account
               can be in cash items, U.S.  Government  securities and securities
               of regulated  investment  companies  (other than  securities of a
               regulated   investment   company  fully  owned  by  the  Variable
               Account).)

               RBSL does not  currently  expect to incur any income tax upon the
               earnings  or  the  realized  capital  gains  attributable  to the
               Variable  Account.  Based upon these  expectations,  no charge is
               being made  currently to the Variable  Account for federal income
               taxes which may be  attributable  to the  Variable  Account.  If,
               however,  RBSL  determines  that it may incur such taxes,  it may
               assess a charge for those taxes from the Variable Account.

               Under  current  laws  RBSL may incur  state  and local  taxes (in
               addition to premium  taxes) in several  states.  At present these
               taxes  are not  significant,  so RBSL is not  currently  making a
               charge for them. If there is material change in such taxes,  RBSL
               may make charges for them against the Variable Account.

          (b)  STATE WHETHER THE TRUST  QUALIFIED FOR THE LAST TAXABLE YEAR AS A
               REGULATED  INVESTMENT  COMPANY AS  DEFINED IN SECTION  851 OF THE
               INTERNAL  REVENUE CODE OF 1954,  AND STATE ITS PRESENT  INTENTION
               WITH RESPECT TO SUCH  QUALIFICATIONS  DURING THE CURRENT  TAXABLE
               YEAR.

               The  Variable  Account has not  qualified  and does not intend to
               qualify as a  regulated  investment  company  during the  current
               taxable year. See the answer to Item 53(a).

VIII. FINANCIAL AND STATISTICAL INFORMATION

     54.  IF THE TRUST IS NOT THE ISSUER OF PERIODIC PAYMENT PLAN  CERTIFICATES,
          FURNISH  INFORMATION  WITH  RESPECT  TO EACH  CLASS OR  SERIES  OF ITS
          SECURITIES.

          Not applicable.

     55.  IF THE TRUST IS THE ISSUER OF PERIODIC  PAYMENT PLAN  CERTIFICATES,  A
          TRANSCRIPT OF A HYPOTHETICAL  ACCOUNT SHALL BE FILED IN  APPROXIMATELY
          THE  FOLLOWING  FORM ON THE BASIS OF THE  CERTIFICATE  CALLING FOR THE
          SMALLEST AMOUNT OF PAYMENTS. THE SCHEDULE SHALL COVER A CERTIFICATE OF
          THE TYPE CURRENTLY BEING SOLD ASSUMING THAT SUCH  CERTIFICATE HAD BEEN
          SOLD  AT  A  DATE  APPROXIMATELY  TEN  YEARS  PRIOR  TO  THE  DATE  OF
          REGISTRATION OR AT THE APPROXIMATE DATE OF ORGANIZATION OF THE TRUST.

          No Policies have yet been issued.

     56.  IF THE TRUST IS THE  ISSUER OF  PERIODIC  PAYMENT  PLAN  CERTIFICATES,
          FURNISH BY YEARS FOR THE PERIOD  COVERED BY THE  FINANCIAL  STATEMENTS
          FILED HEREWITH IN RESPECT TO CERTIFICATES SOLD DURING SUCH PERIOD, THE
          FOLLOWING  INFORMATION  FOR EACH FULLY PAID TYPE AND EACH  INSTALLMENT
          PAYMENT TYPE OF PERIODIC  PAYMENT  PLAN  CERTIFICATE  CURRENTLY  BEING
          ISSUED BY THE TRUST.

          No Policies have yet been issued.

     57.  IF THE TRUST IS THE  ISSUER OF  PERIODIC  PAYMENT  PLAN  CERTIFICATES,
          FURNISH BY YEARS FOR THE PERIOD  COVERED BY THE  FINANCIAL  STATEMENTS
          FILED HEREWITH THE FOLLOWING  INFORMATION FOR EACH INSTALLMENT PAYMENT
          TYPE OF PERIODIC  PAYMENT PLAN  CERTIFICATE  CURRENTLY BEING ISSUED BY
          THE TRUST.

          No Policies have yet been issued.

     58   IF THE TRUST IS THE  ISSUER OF  PERIODIC  PAYMENT  PLAN  CERTIFICATES,
          FURNISH THE FOLLOWING INFORMATION FOR EACH INSTALLMENT PAYMENT TYPE OF
          PERIODIC  PAYMENT  PLAN  CERTIFICATE  OUTSTANDING  AS  AT  THE  LATEST
          PRACTICABLE DATE.

          No Policies have yet been issued.

     59.  FINANCIAL STATEMENTS:

          FINANCIAL STATEMENTS OF THE TRUST

          Financial  Statements  of the Trust will be supplied by  amendment  to
          Registrant's   Registration   Statement  on  Form  S-6,  and  will  be
          incorporated herein by reference.

          FINANCIAL STATEMENTS OF THE DEPOSITOR

          Financial  statements  of  RBSL  will  be  supplied  by  amendment  to
          Registrant's   Registration   Statement  on  Form  S-6,  and  will  be
          incorporated herein by reference.

IX.  EXHIBITS

     A.   (1)  Resolutions  of  Board  of  Directors  of RBSL  establishing  the
               Variable Account.*

          (2)  Not applicable.

          (3)  General Distributor  Agreement and Selling Agreement between RBSL
               and the Distributor.*

          (4)  Not applicable.

          (5)  Form of Policy (together with available Policy riders).*

          (6)  (a)  Articles of Incorporation of RBSL.*

               (b)  Bylaws of RBSL.*

          (7)  Not applicable.

          (8)  Participation Agreements.*

          (9)  Not applicable.

          (10) Policy Application Form.*

         B.       Not applicable.

         C.       Not applicable.

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

         *    Exhibits  have been filed on  December  31,  1996 as part of this
              Form S-6 filing and are incorporated herein by reference.




                                    SIGNATURE

Pursuant to the requirements of the Investment Company Act of 1940 the Depositor
of the  registrant has caused this  registration  statement to be duly signed on
behalf of the  registrant in the City of  Minneapolis  and State of Minnesota on
the ____ day of April, 1997.



(SEAL)                   Signature /s/Richard R. Crowl
                                   --------------------------------------------
                                      Richard R. Crowl
                    ReliaStar Bankers Security Variable Life Separate Account I


                         BY/s/Richard R. Crowl
                           -------------------------------------------------
                              Rickard R. Crown
                              Senior Vice President
                           Reliastar Bankers Security Life Insurance Company


                          BY/s/Richard R. Crowl
                            ------------------------
                               Richard R. Crowl
                               Senior Vice President



Attest: /s/Robert B. Saginaw
        ---------------------------
           Robert B. Saginaw
                  (Name)

         /s/Counsel
         --------------------------
            Counsel
                  (Title)



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