IDS LIFE OF NEW YORK ACCOUNT 4
485APOS, 1995-02-24
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PAGE 1
                SECURITIES AND EXCHANGE COMMISSION

                      Washington, D.C.  20549

                             FORM N-4

REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933             
     
     Post-Effective Amendment No.  1  (File No. 33-52567)        X 

                              and/or

REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940

     Amendment No.  2  (File No. 811-3500)                       X 

                  IDS LIFE OF NEW YORK ACCOUNT 4
                  IDS LIFE OF NEW YORK ACCOUNT 5
                  IDS LIFE OF NEW YORK ACCOUNT 6
                  IDS LIFE OF NEW YORK ACCOUNT 9
                  IDS LIFE OF NEW YORK ACCOUNT 10
                  IDS LIFE OF NEW YORK ACCOUNT 11
___________________________________________________________________
                    (Exact Name of Registrant) 

               IDS Life Insurance Company of New York              
                        (Name of Depositor)

           20 Madison Avenue Extension, Albany, NY 12203           
  (Address of Depositor's Principal Executive Offices) (Zip Code)

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

   Mary Ellyn Minenko, IDS Tower 10, Minneapolis, MN 55440-0010    
              (Name and Address of Agent for Service)

It is proposed that this filing will become effective: May 1, 1995
or as soon as practicable thereafter.

     immediately upon filing pursuant to paragraph (b) of Rule 485
     on (date) pursuant to paragraph (b) of Rule 485
     60 days after filing pursuant to paragraph (a)(i) of Rule 485
 X   on May 1, 1995 pursuant to paragraph (a)(i) of Rule 485
____ 75 days after filing pursuant to paragraph (a)(ii) of Rule 485
____ on (date) pursuant to paragraph (a)(ii) of Rule 485

If appropriate, check the following box:

____  this post-effective amendment designates a new effective date
      for previously filed post-effective amendment.

The Registrant has registered an indefinite number or amount of
securities under the Securities Act of 1933 pursuant to Section 
24-f of the Investment Company Act of 1940.  Registrant's Rule 
24f-2 Notice for its most recent fiscal year was filed on or about
February 28, 1995.
<PAGE>
PAGE 2
                       CROSS REFERENCE SHEET
<TABLE>
<CAPTION>
Cross reference sheet showing location in the prospectus and Statement of Additional Information
of the information called for by the items enumerated in Part A and B of Form N-4.

Negative answers omitted from prospectus and Statement of Additional Information are so indicated.

          PART A                                 PART B
 
                                                        Section in
                  Section                               Statement of
  Item No.        in Prospectus            Item No.     Additional Information
    <C>             <C>                      <C>          <C>
    1               Cover page               15           Cover page

    2               Key terms                16           Table of contents

    3(a)            Expense summary          17(a)        NA
     (b)            The Employee Benefit       (b)        NA
                    Annuity in brief           (c)        About Life of New York*

    4(a)            Condensed financial      18(a)        NA
                    information                (b)        NA
     (b)            Performance information    (c)        Independent auditors
     (c)            Financial statements       (d)        NA
                                               (e)        NA
    5(a)            Cover page; About IDS      (f)        NA
                    Life of New York
     (b)            The variable accounts    19(a)        Distribution of the contracts*;
     (c)            The funds                             About IDS Life of New York*
     (d)            Cover page; The funds      (b)        Certificate charges*
     (e)            Voting rights
     (f)            NA                       20(a)        Principal underwriter
     (g)            NA                         (b)        Principal underwriter
                                               (c)        Principal underwriter
    6(a)            Certificate charges        (d)        NA
     (b)            Certificate charges
     (c)            Certificate charges      21(a)        Performance information
     (d)            Distribution of the        (b)        Performance information
                    certificates
     (e)            The funds                22           Calculating annuity payouts
     (f)            NA
                                             23(a)        NA
    7(a)            Buying the contract and    (b)        NA
                    certificate; Benefits
                    in case of death; The
                    annuity payout period
     (b)            The variable accounts;
                    Making the most of your
                    annuity
     (c)            The funds; Certificate charges
     (d)            Cover page

    8(a)            The annuity payout period
     (b)            Buying the contract and
                    certificate
     (c)            The annuity payout period
     (d)            The annuity payout period
     (e)            The annuity payout period
     (f)            The annuity payout period

    9(a)            Benefits in case of death
     (b)            Benefits in case of death

   10(a)            Buying the contract and
                    certificate; Valuing your
                    investment
     (b)            Valuing your investment
     (c)            Buying the contract and
                    certificate; Valuing your
                    investment
     (d)            About Life of New York

<PAGE>
PAGE 3

   11(a)            Surrendering a certificate
     (b)            NA
     (c)            Surrendering a certificate
     (d)            Buying the contract and
                    certificate
     (e)            The Employee Benefit Annuity
                    in brief

   12(a)            Taxes
     (b)            Key terms
     (c)            NA

   13               NA

   14               Table of contents of the
                    Statement of Additional Information

*Designates section in the prospectus, which is hereby incorporated by reference in this Statement
of Additional Information.
</TABLE>
<PAGE>
PAGE 4
   
IDS Life of New York Employee Benefit Annuity

Prospectus
May 1, 1995

The Employee Benefit Annuity is a flexible premium group deferred
fixed/variable annuity contract (the contract) offered by IDS Life
Insurance Company of New York (IDS Life of New York) a subsidiary
of IDS Life Insurance Company (IDS Life), which is a subsidiary of
American Express Financial Corporation.  Participation in the
contract will be accounted for separately by the issuance of a
certificate showing the participant's interest under the contract.
    
The contract is a group deferred annuity in which purchase payments
are accumulated on a fixed and/or variable basis and retirement
benefits are paid to the participant on a fixed or variable basis
or a combination of both.  It is available for an employer-
sponsored plan and a salary-reduction plan that meets the
requirements of Section 403(b) of the Code (the plan).
   
IDS Life of New York Accounts 4, 5, 6, 9, 10 and 11

Sold by:  IDS Life Insurance Company of New York, 20 Madison Avenue
Extension, Albany, NY 12203, Telephone: (518) 869-8613.
    
THIS PROSPECTUS CONTAINS THE INFORMATION ABOUT THE VARIABLE
ACCOUNTS THAT YOU SHOULD KNOW BEFORE INVESTING.  Refer to "The
variable accounts" in this prospectus.

THE PROSPECTUS IS ACCOMPANIED OR PRECEDED BY THE RETIREMENT ANNUITY
MUTUAL FUND PROSPECTUS FOR IDS LIFE AGGRESSIVE GROWTH FUND, IDS
LIFE INTERNATIONAL EQUITY FUND, IDS LIFE CAPITAL RESOURCE FUND, IDS
LIFE MANAGED FUND, INC., IDS LIFE SPECIAL INCOME FUND, INC. AND IDS
LIFE MONEYSHARE FUND, INC.  PLEASE KEEP THESE PROSPECTUSES FOR
FUTURE REFERENCE.

THESE SECURITIES HAVE NOT BEEN APPROVED OR DISAPPROVED BY THE
SECURITIES AND EXCHANGE COMMISSION, OR ANY STATE SECURITIES
COMMISSION, NOR HAS THE SECURITIES AND EXCHANGE COMMISSION OR ANY
STATE SECURITIES COMMISSION PASSED UPON THE ACCURACY OR ADEQUACY OF
THIS PROSPECTUS.  ANY REPRESENTATION TO THE CONTRARY IS A CRIMINAL
OFFENSE.

IDS LIFE OF NEW YORK IS NOT A BANK AND THE SECURITIES IT OFFERS ARE
NOT DEPOSITS OR OBLIGATIONS OF, OR GUARANTEED OR ENDORSED BY ANY
BANK NOR ARE THEY INSURED BY THE FEDERAL DEPOSIT INSURANCE
CORPORATION, THE FEDERAL RESERVE BOARD OR ANY OTHER AGENCY.
   
A Statement of Additional Information (SAI) dated May 1, 1995
(incorporated by reference into this prospectus) has been filed
with the Securities and Exchange Commission (SEC), and is available
without charge by contacting IDS Life of New York at the telephone
number above or by completing and sending the order form on the
last page of this prospectus.  The table of contents of the SAI is
on the last page of this prospectus.
    
<PAGE>
PAGE 5
   
                         Table of Contents

Key terms.......................................................
The Employee Benefit Annuity in brief...........................
Expense summary.................................................
Condensed financial information.................................
Financial statements............................................
Performance information.........................................
The variable accounts...........................................
The funds.......................................................
     Aggressive Growth Fund.....................................
     International Equity Fund..................................
     Capital Resource Fund......................................
     Managed Fund...............................................
     Special Income Fund........................................
     Moneyshare Fund............................................
The fixed account...............................................
Buying the contract and certificate.............................
     Setting the retirement date................................
     Beneficiary................................................
     How to make purchase payments..............................
Certificate charges.............................................
     Administrative charge......................................
     Mortality and expense risk fee.............................
     Surrender charge...........................................
Valuing your investment.........................................
     Number of units............................................
     Accumulation unit value....................................
     Net investment factor......................................
     Factors that affect variable account
     accumulation units.........................................
Making the most of your annuity.................................
     Automated dollar-cost averaging............................
     Transferring money between accounts........................
     Transfer policies..........................................
     How to request a transfer or a surrender...................
Surrendering a certificate......................................
     Surrender policies.........................................
     Receiving payment when a participant requests
     a surrender................................................
TSA special surrender provisions................................
Changing ownership..............................................
Benefits in case of death.......................................
The annuity payout period.......................................
     Annuity payout plans.......................................
     Death after annuity payouts begin..........................
     Transfers between accounts after annuity payouts begin.....
Taxes...........................................................
Voting rights...................................................
Substitution....................................................
Distribution of the certificates................................
About IDS Life of New York......................................
Regular and special reports.....................................
Table of contents of the Statement of Additional Information....
    
<PAGE>
PAGE 6
Key terms

These terms can help you understand details about your annuity.

Annuity - A contract purchased from an insurance company that
offers tax-deferred growth of the investment until earnings are
withdrawn, and that can be tailored to meet the specific needs of
the individual during retirement.

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

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

Annuity payouts - An amount paid at regular intervals under one of
several plans available to a participant and/or any other payee. 
This amount may be paid on a variable or fixed basis or a
combination of both. 

Annuity unit - A measure of the value of each variable account used
to calculate the annuity payouts a participant receives. 

Beneficiary - The person designated to receive annuity benefits in
case of a participant's death.  Each participant may name a
beneficiary in accordance with the applicable provisions of any
plan and the Code.

Certificate - The document delivered to each participant that
evidences the participant's coverage under the contract.

Certificate value - The total value of the certificate before any
applicable surrender charge and any administrative charge have been
deducted.

Certificate year - A period of 12 months, starting on the effective
date of the certificate and on each anniversary of the effective
date.

Close of business - When the New York Stock Exchange (NYSE) closes,
normally 3 p.m. Central time.

Code - Internal Revenue Code of 1986, as amended.

Contract owner (owner) - The person or party entitled to ownership
rights stated in the contract and in whose name the contract is
issued.
   
Fixed account - An account to which a participant may allocate
purchase payments.  Amounts allocated to this account earn interest
at rates that are declared periodically by IDS Life of New York.

IDS Life of New York - In this prospectus, "we," "us," "our," and
"IDS Life of New York" refer to IDS Life Insurance Company of New
York.
    
<PAGE>
PAGE 7
Mutual funds (funds) - Six IDS Life Retirement Annuity mutual
funds, each with a different investment objective.  (See "The
funds.")  Purchase payments can be allocated into variable accounts
investing in shares of any or all of these funds.

Participant - The person named in the certificate who is entitled
to exercise all rights and privileges of ownership under the
certificate, except as reserved by the owner.  In this prospectus,
"you" and "your" refer to the participant.
   
Purchase payments - Payments made to IDS Life of New York under the
contract by or on behalf of a participant.
    
Retirement date - The date when annuity payouts are scheduled to
begin.  This date is first established when enrollment in the
certificates takes place, subject to the terms of the plan.  It can
be changed in the future.
 
Surrender charge - A deferred sales charge that may be applied if a
participant surrenders the certificate before the retirement date.

Surrender value - The amount a participant is entitled to receive
if the certificate is surrendered.  It is the certificate value
minus any applicable surrender charge and administrative charge. 

Valuation date - Any normal business day, Monday through Friday,
that the NYSE is open.  The value of each variable account is
calculated at the close of business on each valuation date.

Variable accounts - Six separate accounts to which a participant
may allocate purchase payments; each invests in shares of one
mutual fund.  (See "The variable accounts.")  The value of your
investment in each variable account changes with the performance of
the particular fund.

The Employee Benefit Annuity in brief

Purpose:  The Employee Benefit Annuity is designed to allow you to
build up funds for retirement.  This is done by making one or more
investments (purchase payments) that may earn returns that increase
the value of your certificate.  Beginning at a specified future
date (the retirement date), the contract and related certificate
provide you with lifetime or other forms of annuity payouts. 
   
Ten-day free look: You may return a certificate to the financial
advisor or our Minneapolis office within 10 days after it is
delivered and receive a full refund of the certificate value.  No
charges will be deducted.
    
Accounts:  You may allocate purchase payments among any or all of:

o  six variable accounts, each of which invests in mutual funds
   with a particular investment objective.  The value of each
   variable account varies with the performance of the particular
<PAGE>
PAGE 8
   fund.  We cannot guarantee that the value at the retirement date
   will equal or exceed the total of purchase payments allocated to
   the variable accounts.  (p.)
   
o  one fixed account, which earns interest at rates that are
   adjusted periodically by IDS Life of New York.  (p.)  

Buying the contract and certificate:  A financial advisor will help
the owner complete and submit an application for a contract and
help you complete and submit an enrollment form for the
certificate.  Applications and enrollment forms are subject to
acceptance at our Albany office.  The maximum amount of purchase
payments is determined by any restrictions imposed by the plan and
the Code.
    
o  Minimum purchase payment - ($1,000) unless you pay in
   installments under a group billing arrangement such as a
   payroll deduction.
o  Minimum installment payment - $25 monthly or $300 annually
o  Maximum first-year payment(s) - $50,000 to $1,000,000 depending
   on your age.
o  Maximum payment for each subsequent year - $50,000. (p.)

Transfers: Subject to certain restrictions you may redistribute
money among accounts without charge at any time until annuity
payouts begin, and once per year among the variable accounts
thereafter.  You may establish automated transfers among the fixed
and variable account(s).  (p.)

Surrenders:  You may surrender all or part of your certificate
value at any time before the retirement date subject to certain
restrictions imposed by the Code and the plan.  Surrenders may be
subject to charges and tax penalties and may have other tax
consequences.  (p.)

Changing ownership:  Restrictions apply concerning change of
ownership of rights under a contract or certificate.  (p.)

Payment in case of death:  If the participant dies before annuity
payouts begin, we will pay the beneficiary an amount at least equal
to the certificate value.  (p.)

Annuity payouts:  The certificate value of your investment can be
applied to an annuity payout plan that begins on the retirement
date.  You may choose from a variety of plans to make sure that
payouts continue as long as they are needed.  Payouts may be made
on a fixed or variable basis, or both.  Total monthly payouts
include amounts from each variable account and the fixed account. 
(p.)
   
Taxes:  Generally your certificate value grows tax deferred until
you surrender it or begin to receive payouts.  (Under certain
circumstances, IRS penalty taxes may apply.)  Even if you direct 
payouts to someone else, you will still be taxed on the
distribution.  (p.)
    
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PAGE 9
   
Charges:  Your certificate is subject to an annual administrative
charge of $30, a 1% mortality and expense risk charge and an 8%
declining surrender charge on purchase payments up to eleven
contract years old.  (p.)
    
Expense summary

The purpose of this summary is to help the owner and participant
understand the various costs and expenses associated with the
contract and related certificates.

There is no sales charge when purchasing the contract or
certificate.  All direct and indirect costs for the variable
accounts and underlying mutual funds are shown below.  Some
expenses may vary as explained under "Certificate charges."

Direct charges.  These are deducted directly from the certificate
value.  They include:

Surrender charge:  A surrender charge applies to surrenders within
the first 11 certificate years.  The surrender charge is 8% of the
amount surrendered in the first through fourth certificate years,
and then declines by 1% per year from 7% in the fifth certificate
year to 1% in the 11th certificate year. The surrender charge is
further limited so that it will never exceed 8.5% of aggregate
purchase payments made to the certificate.

Annual administrative charge:  $30.

Indirect charges.  The variable account pays these expenses out of
its assets.  They are reflected in the variable account's daily
accumulation unit value and are not charged directly to the
account.  They include:

Mortality and expense risk fee:  1% per year, deducted from the
variable account as a percentage of the average daily net assets of
the underlying fund.

Operating expenses of underlying mutual funds:  management fees and
other expenses deducted as a percentage of average net assets as
follows:  *
   
<TABLE>
<CAPTION>
                        Aggressive     International      Capital                 Special
                          Growth           Equity         Resource     Managed    Income      Moneyshare
  <S>                      <C>             <C>              <C>         <C>        <C>           <C>
  Management fees          .64%             .89%            .64%        .64%       .64%          .54%

  Other expenses           .04%             .16%            .04%        .04%       .04%          .02%

  Total**                  .68%            1.05%            .68%        .68%       .68%          .56%
</TABLE>

* Premium taxes imposed by some state and local governments are not
reflected in this table.

**Annualized operating expenses of underlying mutual funds at Dec.
31, 1994.
    <PAGE>
PAGE 10
Example*

As a participant, you would pay the following expenses on a $1,000
investment, assuming 5% annual return and surrender at the end of
each time period:
   
<TABLE>
<CAPTION>
                      Aggressive     International     Capital                 Special
                        Growth           Equity        Resource      Managed   Income      Moneyshare
  <S>                 <C>            <C>               <C>           <C>       <C>         <C>
  1 year

  3 years

  5 years

  10 years

  You would pay the following expenses on the same investment assuming no surrender or selection of an
  annuity payout plan at the end of each period:

  1 year

  3 years

  5 years

  10 years
</TABLE>
    
This example should not be considered a representation of past or
future expenses.  Actual expenses may be more or less than those
shown.
   
* In this example, the $30 annual administrative charge is
approximated as a .290% charge based on our average certificate
size.
    
Condensed financial information
(unaudited)

The following tables give per-unit information about the financial
history of each variable account.
   
Financial statements

The SAI dated May 1, 1995, contains:

o     complete audited financial statements of the variable
      accounts including:
      - statements of net assets as of Dec. 31, 1994;
      - statements of operations for the year ended Dec. 31, 1994;
      and
      - statements of changes in net assets for the years ended
      Dec. 31, 1994 and Dec. 31, 1993.

o     complete audited financial statements for IDS Life including:
      - consolidated balance sheets as of Dec. 31, 1994 and Dec.
      31, 1993; and
      - related consolidated statements of income and cash flows
      for each of three years in the period ended Dec. 31, 1994.
    
<PAGE>
PAGE 11
Performance information

Performance information for the variable accounts may appear from
time to time in advertisements or sales literature.  In all cases,
such information reflects the performance of a hypothetical
investment in a particular account during a particular time period. 
Calculations are performed as follows:
   
Simple yield - Account 6 (investing in Moneyshare Fund):  Income
over a given seven-day period (not counting any change in the
capital value of the investment) is annualized (multiplied by 52)
by assuming that the same income is received for 52 weeks.  This
annual income is then stated as an annual percentage return on the
investment.

Compound yield - Account 6:  Calculated like simple yield, except
that, when annualized, the income is assumed to be reinvested. 
Compounding of reinvested returns increases the yield as compared
to a simple yield.

Yield - Account 5 (investing in Special Income):  Net investment
income (income less expenses) per accumulation unit during a given
30-day period is divided by the value of the unit on the last day
of the period.  The result is converted to an annual percentage.
    
Average annual total return:  Expressed as an average annual
compounded rate of return of a hypothetical investment over a
period of one, five and 10 years (or up to the life of the account
if it is less than 10 years old).  This figure reflects deduction 
of all applicable charges, including the administrative charge,
mortality and expense risk fee and surrender charge, assuming a
surrender at the end of the illustrated period.  Optional total
return quotations may be made that do not reflect a surrender
charge deduction (assuming no surrender).
   
Aggregate total return:  Represents the cumulative change in the
value of an investment for a specified period of time (reflecting
change in an account's accumulation unit value).  The calculation
assumes reinvestment of investment earnings.  Aggregate total
return may be shown by means of schedules, charts or graphs.
    
Performance information should be considered in light of the
investment objectives and policies, characteristics and quality of
the fund in which the account invests, and the market conditions
during the given time period.  Such information is not intended to
indicate future performance.  Because advertised yields and total
return figures include all charges attributable to the
certificates, which has the effect of decreasing advertised
performance, account performance should not be compared to that of
mutual funds that sell their shares directly to the public.  (See
the SAI for a further description of methods used to determine
yield and total return for the accounts.)

<PAGE>
PAGE 12
   
If you would like additional information about actual performance,
contact your financial advisor.
    
The variable accounts

Purchase payments can be allocated to any or all of the variable
accounts that invest in shares of the following funds:
   
                              IDS Life of
                            New York Account      Established

Aggressive Growth Fund           11               Oct. 8, 1991
International Equity Fund        10               Oct. 8, 1991
Capital Resource Fund            4                Nov. 12, 1981
Managed Fund                     9                Feb. 12, 1986
Special Income Fund              5                Nov. 12, 1981
Moneyshare Fund                  6                Nov. 12, 1981

Each variable account meets the definition of a separate account
under federal securities laws.  Income, capital gains and capital
losses of each account are credited or charged to that account
alone.  No variable account will be charged with liabilities of any
other account or of our general business.  Each variable account's
net assets are held in relation to the contracts described in the
prospectus as well as other variable annuity contracts that we
issue that are not described in this prospectus.  All obligations
arising under the contracts are general obligations of IDS Life of
New York.

All variable accounts were established under New York law and are
registered together as a single unit investment trust under the
Investment Company Act of 1940 (the 1940 Act).  This registration 
does not involve any supervision of our management or investment
practices and policies by the SEC.
    
The funds

Aggressive Growth Fund
Objective: capital appreciation.  Invests primarily in common stock
of small- and medium-size companies.  The fund also may invest in
warrants or debt securities or in large well-established companies
when the portfolio manager believes such investments offer the best
opportunity for capital appreciation.

International Equity Fund
Objective: capital appreciation.  Invests primarily in common stock
of foreign issuers and foreign securities convertible into common
stock.  The fund also may invest in certain international bonds if
the portfolio manager believes they have a greater potential for
capital appreciation than equities.  

Capital Resource Fund
Objective: capital appreciation.  Invests primarily in U.S. common
stocks listed on national securities exchanges and other securities
convertible into common stock, diversified over many different
companies in a variety of industries.
<PAGE>
PAGE 13
Managed Fund
Objective: maximum total investment return.  Invests primarily in
U.S. common stocks listed on national securities exchanges,
securities convertible into common stock, warrants, fixed income
securities (primarily high-quality corporate bonds) and
money-market instruments.  The fund invests in many different
companies in a variety of industries.

Special Income Fund
Objective: to provide a high level of current income while
conserving the value of the investment for the longest time period. 

Invests primarily in high-quality, lower-risk corporate bonds
issued by many different companies in a variety of industries, and
in government bonds. 

Moneyshare Fund
Objective: maximum current income consistent with liquidity and
conservation of capital.  Invests in high-quality money market
securities with remaining maturities of 13 months or less.  The
fund also will maintain a dollar-weighted average portfolio
maturity not exceeding 90 days.  The fund attempts to maintain a
constant net asset value of $1 per share.

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

The U.S. Treasury and the IRS have indicated they may provide
additional guidance concerning how many variable accounts may be
offered and how many exchanges among variable accounts may be
allowed before the participant is considered to have investment
control and thus is currently taxed on income earned within
variable account assets.  We do not know at this time what the
additional guidance will be or when action will be taken.  We 
reserve the right to modify the contract/certificate, as necessary,
to ensure that the participant will not be subject to current
taxation as the owner of the variable account assets.

We intend to comply with all federal tax laws to ensure that the
contract/certificate continues to qualify as an annuity for federal
income tax purposes.  We reserve the right to modify the 
contract/certificate as necessary to comply with any new tax laws.
   
IDS Life is the investment adviser for each of the funds.  IDS Life
cannot guarantee that the funds will meet their investment
objectives.  Please read the Retirement Annuity Mutual Fund
prospectus for complete information on investment risks,
deductions, expenses and other facts you should know before
investing.  It is available by contacting IDS Life of New York at
the address or telephone number on the front of this publication,
or from your financial advisor.
    
<PAGE>
PAGE 14
The fixed account 
   
Purchase payments can also be allocated to the fixed account. The
cash value of the fixed account increases as interest is credited
to the account.  Purchase payments and transfers to the fixed
account become part of the general account of IDS Life of New York,
the company's main portfolio of investments.  Interest is credited
daily and compounded annually.  We may change the interest rates
from time to time.
    
Because of exemptive and exclusionary provisions, interests in the
fixed account have not been registered under the Securities Act of
1933 (1933 Act), nor is the fixed account registered as an
investment company under the 1940 Act.  Accordingly, neither the 
fixed account nor any interests in it are generally subject to the
provisions of the 1933 or 1940 Acts, and we have been advised that
the staff of the SEC has not reviewed the disclosures in this
prospectus that relate to the fixed account.  Disclosures regarding
the fixed account, however, may be subject to certain generally
applicable provisions of the federal securities laws relating to
the accuracy and completeness of statements made in prospectuses.

Buying the contract and certificate
   
A financial advisor will help the owner prepare and submit an
application.  A financial advisor will also help each participant
prepare and submit an enrollment form.  These forms will be sent to
our Albany office.  Unless otherwise provided in the contract, the
owner has all rights under the contract.  Your interest under the
contract, as evidenced by your certificate, is subject to the terms
of the owner's contract and the plan.    
    
When you enroll in the certificate, you can select:

o  the account(s) in which you want to invest;
o  the date you want to start receiving annuity payouts (the
   retirement date); and
o  a beneficiary.

The owner selects the frequency with which it will make purchase
payments.

If the application and enrollment forms are complete, we will
process them within two days after we receive them.  If the
application is accepted, we will send the owner a contract.  If
your enrollment form is accepted, we will send you a certificate. 
If we cannot accept an application or enrollment form within five
days, we will decline it and return any payment.  We will credit
additional purchase payments to the account(s) at the next close of
business.

<PAGE>
PAGE 15
Setting the retirement date 

Annuity payouts will be scheduled to begin on the retirement date.
This date can be aligned with actual retirement from a job, or it
can be a different future date, depending on your needs and goals 
and on certain restrictions.  You can also change the date,
provided you send us written instructions at least 30 days before
annuity payouts begin.

To avoid IRS penalty taxes, the retirement date generally must be:

o  on or after you reach age 59 1/2; and
o  by April 1 of the year following the calendar year when you
   reach age 70 1/2.

If you are taking the minimum 403(b) plan distributions as required
by the Code from another tax-qualified investment, or in the form
of partial surrenders under the certificate, retirement payments
can start as late as your 85th birthday or the 10th contract
anniversary.
       
Beneficiary

If death benefits become payable before the retirement date, your
named beneficiary will receive all or part of the certificate
value.  If there is no named beneficiary, then your estate will be
the beneficiary.  (See "Payment in case of death" for more about
beneficiaries.)

Minimum purchase payments

$25 monthly

Installments must total at least $300 per year*
   
*If no purchase payments have been made on a participant's behalf
for 36 months, and previous payments total $600 or less, we have
the right to pay the participant the total value of the certificate
in a lump sum.
    
Minimum lump sum purchase payment

Initial payment:    $1,000

Minimum additional purchase payment(s):    $50

Maximum first - year payment(s):

This maximum is based the participant's age on the effective date
of the certificate.

Up to age 75             $1 million
76 to 85                 $500,000
86 to 90                 $50,000
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PAGE 16
Maximum payment for each subsequent year:    $50,000**
   
**These limits apply in total to all IDS Life of New York annuities
you own.  We reserve the right to increase maximum limits or reduce
age limits.  The plan's limits on annual contribution also apply.   
   
How to make purchase payments

By scheduled payment plan:  A financial advisor can help the owner
set up an automatic salary reduction arrangement.
    
Certificate charges 

Administrative charge
This fee is for establishing and maintaining records for each
certificate under the contract.  We deduct $30 from the certificate
value at the end of each certificate year.

If a participant surrenders a certificate, the annual charge will
be deducted at the time of surrender.  The annual charge cannot be
increased and does not apply after annuity payouts begin.

Mortality and expense risk fee

This fee is to cover the mortality risk and expense risk and is
applied daily to the variable accounts and reflected in the unit
values of the accounts.  Annually it totals 1% of their average
daily net assets.  Approximately two-thirds of this amount is for
our assumption of mortality risk, and one-third is for our
assumption of expense risk.  This fee does not apply to the fixed
account.
   
Mortality risk arises because of our guarantee to pay a death
benefit and our guarantee to make annuity payouts according to the
terms of the contract and certificates, no matter how long a
specific annuitant lives and no matter how long the entire group of
IDS Life of New York annuitants live.  If, as a group, IDS Life of
New York annuitants outlive the life expectancy we have assumed in
our actuarial tables, then we must take money from our general
assets to meet our obligations.  If, as a group, IDS Life of New
York annuitants do not live as long as expected, we could profit
from the mortality risk fee.
    
Expense risk arises because the administrative charge cannot be
increased and may not cover our expenses.  Any deficit would have
to be made up from our general assets.  We could profit from the
expense risk fee if the annual administrative charge is more than
sufficient to meet expenses.

We do not plan to profit from the administrative charge.  However,
we do hope to profit from the mortality and expense risk fee.  We
may use any profits realized from this fee for any proper corporate
purpose, including, among others, payment of distribution (selling)
<PAGE>
PAGE 17
expenses.  We do not expect that the surrender charge, discussed in
the following paragraphs, will cover sales and distribution
expenses.

Surrender charge  
If part or all of a certificate is surrendered within the first 11
certificate years, the following surrender charge applies:

                                           Surrender Charge as
                                               Percent of
Certificate Year                           Amount Surrendered 
       1                                           8%
       2                                           8
       3                                           8
       4                                           8
       5                                           7
       6                                           6
       7                                           5
       8                                           4
       9                                           3
       10                                          2
       11                                          1
12 and later                                       0          
   
The surrender charge is further limited so that it will never
exceed 8.5% of aggregate purchase payments made to the certificate. 
IDS Life of New York reserves the right to reduce or eliminate the
surrender charge.
    
In the case of a partial surrender, the surrender charge is
deducted from the certificate value remaining after you are paid
the partial surrender amount requested.  For example, if you
requested a partial surrender net check amount of $1,000 and the
surrender charge rate were 5%, you would receive the $1,000
requested and the surrender charge amount would be $52.63 for a
total withdrawal from the certificate of $1,052.63.

No surrender charge:  There is no surrender charge on amounts
surrendered:

o  after the 11th certificate year;
o  due to a participant's retirement under the plan on or after age
   55;
o  due to the death of the participant; or
o  upon settlement of the certificate under an annuity payout plan.
   
Possible group reductions: In some cases lower sales and
administrative expenses may be incurred due to the size of the
group, the average contribution and the use of group enrollment
procedures.  In such cases, we may be able to reduce or eliminate
the administrative and surrender charges.  However, we expect this
to occur infrequently.
    
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PAGE 18
Valuing your investment

Here is how your accounts are valued:

Fixed account:  The amounts allocated to the fixed account are
valued directly in dollars and equal the sum of your purchase
payments, plus interest earned, less any amounts surrendered or
transferred.
   
Variable accounts:  Amounts allocated to the variable accounts are
converted into accumulation units.  Each time you make a purchase
payment or transfer amounts into one of the variable accounts, a
certain number of accumulation units are credited to your
certificate for that account.  Conversely, each time you take a
partial surrender, transfer amounts out of a variable account, or
are assessed an administrative charge, a certain number of
accumulation units are subtracted from your certificate.
    
The accumulation units are the true measure of investment value in
each account during the accumulation period.  They are related to,
but not the same as, the net asset value of the underlying fund. 
The dollar value of each accumulation unit can rise or fall daily
depending on the performance of the underlying mutual fund and on
certain fund expenses.  Here is how unit values are calculated:
   
Number of units
To calculate the number of accumulation units for a particular
account, we divide the investment by the current accumulation unit
value.
    
Accumulation unit value
The current accumulation unit value for each variable account
equals the last value times the account's current net investment
factor.

Net investment factor
o  Determined each business day by adding the underlying mutual
   fund's current net asset value per share, plus per share amount
   of any current dividend or capital gain distribution; then
o  dividing that sum by the previous net asset value per share; and
o  subtracting the percentage factor representing the mortality and
   expense risk fee from the result.

Because the net asset value of the underlying mutual fund may
fluctuate, the accumulation unit value may increase or decrease.  
The investor bears this investment risk in a variable account.

Factors that affect variable account accumulation units
Accumulation units may change in two ways; in number and in value. 
Here are the factors that influence those changes:
   
The number of accumulation units you own may fluctuate due to:

o  additional purchase payments allocated to the variable
   account(s);
    
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PAGE 19
o  transfers into or out of the variable account(s);
o  partial surrenders;
o  surrender charges; and/or
o  administrative charges.

Accumulation unit values may fluctuate due to:

o  changes in underlying mutual fund(s) net asset value;
o  dividends distributed to the variable account(s);
o  capital gains or losses of underlying mutual funds;
o  mutual fund operating expenses; and/or
o  mortality and expense risk fees.

Making the most of your certificate

Automated dollar-cost averaging 
You can use automated transfers to take advantage of dollar-cost
averaging (investing a fixed amount at regular intervals).  For
example, you might have a set amount transferred monthly from a
relatively conservative variable account to a more aggressive one,
or to several others.
   
This systematic approach can help you benefit from fluctuations in
accumulation unit values caused by fluctuations in the market
value(s) of the underlying mutual fund(s).  Since you invest the
same amount each period, you automatically acquire more units when
the market value falls, fewer units when it rises.  The potential
effect is to lower the average cost per unit.  For specific
features contact your financial advisor.
    
How dollar-cost averaging works

         Amount      Accumulation    Number of units
Month    invested    unit value      purchased

Jan      $100          $20           5.00
Feb       100           16           6.25
Mar       100            9          11.11
Apr       100            5          20.00
May       100            7          14.29
June      100           10          10.00
July      100           15           6.67
Aug       100           20           5.00
Sept      100           17           5.88
Oct       100           12           8.33

(footnotes to table) By investing an equal number of dollars each
month...

(arrow in table pointing to April) you automatically buy more units
when the per unit market price is low

(arrow in table pointing to August) and fewer units when the per
unit market price is high.

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PAGE 20
You have paid an average price of only $10.81 per unit over the 10
months, while the average market price actually was $13.10.

Dollar-cost averaging does not guarantee that any variable account
will gain in value, nor will it protect against a decline in value
if market prices fall.  However, if you can continue to invest
regularly throughout changing market conditions, it can be an
effective strategy to help meet your long term goals.

Transferring money between accounts
You may transfer money from one account, including the fixed
account, to another before the annuity payouts begin.  If we
receive your request before the close of business, we will process
it that day.  Requests received after the close of business will be
processed the next business day.  There is no charge for transfers. 
Before making a transfer, you should consider the risks involved in
switching investments.

We may suspend or modify transfer privileges at any time.  Certain
restrictions apply to transfers involving the fixed account.  In
addition, any restriction imposed by the plan will apply.  (For
information on transfers after annuity payouts begin, see "The
annuity payout period.")

Transfer policies
o  Subject to any restrictions imposed by the plan, you may
   transfer certificate values between the variable accounts, or
   from the variable account(s) to the fixed account at any time.
   However, if a transfer has been made from the fixed account to
   the variable account(s), you may not make a transfer from any
   variable account back to the fixed account until the next
   eligible transfer period as defined in the plan, if any, or
   otherwise until the next certificate anniversary.

o  You may transfer certificate values from the fixed account to
   the variable account(s) once per certificate year, (except for 
   automated transfers, which can be set up for transfer periods of
   your choosing subject to certain minimums.)

o  No transfers may be made to or from the fixed account once
   annuity payouts begin.
   
How to request a transfer or a surrender

1    By letter

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

Regular mail:
IDS Life Insurance Company of New York
Box 1544
Albany, NY 12205
    
<PAGE>
PAGE 21
   
Express mail:
IDS Life Insurance Company of New York
20 Madison Avenue Extension
Albany, NY 12203
    
Minimum amount
Mail transfers:     $250 or entire account balance 
Mail surrenders:    $250 or entire account balance

Maximum amount
Mail transfers:     None (up to the certificate value)
Mail surrenders:    None (up to the certificate value)
   
2    By automated transfers

Your financial advisor can help you set up automated transfers  
among your accounts.

You can start or stop this service by written request or other
method acceptable to IDS Life of New York after the service has
been in effect for a period of 12 consecutive months.  You must
allow 30 days for IDS Life of New York to change any instructions
that are currently in place.
    
o  Automated transfers from the fixed to variable account(s) may
   not exceed an amount that, if continued, would deplete the fixed
   account within 12 months.

o  Automated transfers are subject to all of the contract
   provisions and terms, including transfer of certificate values
   between accounts.  

Minimum amount
Automated transfers:     $50   
                                        
Maximum amount
Automated transfers:     None (except for automated transfers 
                         from the fixed account)

Surrendering a certificate

Subject to certain restrictions imposed by the Code and any
restrictions imposed by the plan, you may surrender all or part of
your certificate at any time before annuity payouts begin by
sending a written request or calling us.  For total surrenders we
will compute the value of the certificate at the close of business
after we receive the request.  We may ask you to return the
certificate.  You may have to pay surrender charges (see "Surrender
charge") and IRS taxes and penalties (see "Taxes").  No surrenders
may be made after annuity payouts begin.

Surrender policies
If you have a balance in more than one account and request a
partial surrender, we will withdraw money from all of your accounts
in the same proportion as your value in each account correlates to
the total certificate value, unless requested otherwise.
<PAGE>
PAGE 22
Receiving payment when a participant requests a surrender

By regular or express mail:

o  Payable to participant.
   
o  Mailed to address of record.

By Wire:

o  Request that payment be wired to your bank;

o  Bank account must be in the same ownership as your contract;

o  Pre-authorization required.  For instructions, contact your
   financial advisor.

Payment normally will be sent within seven days after receiving the
request.  However, we may postpone the payment if:
      -the surrender amount includes a purchase payment check that
      has not cleared;
      -the NYSE is closed, except for normal holiday and weekend
      closings;
      -trading on the NYSE is restricted, according to SEC rules;
      -an emergency, as defined by SEC rules, makes it impractical
      to sell securities or value the net assets of the accounts;
      or
      -the SEC permits us to delay payment for the protection of
      security holders.
    
TSA-special surrender provisions
The Code imposes certain restrictions on a participant's right to
receive early distributions attributable to salary reduction
contributions from a Tax Sheltered Annuity (TSA):

o  Distributions attributable to salary reduction contributions
   made after Dec. 31, 1988, plus the earnings on them, or to
   transfers or rollovers of such amounts from other contracts, may
   be made from the TSA only if:
      -the participant has attained age 59-1/2;
      -the participant has become disabled as defined in the Code;
      -the participant has separated from the service of the
      employer who purchased the contract; or
      -the distribution is made to the participant's beneficiary
      because of death.

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

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

<PAGE>
PAGE 23
o  The above restrictions on the right to receive a distribution do
   not affect the availability of the amount transferred or rolled
   over to the certificate as of Dec. 31, 1988.  The restrictions   
   do not apply to transfers or exchanges of certificate values     
   within the annuity, or to another registered variable annuity    
   contract or investment vehicle availablethrough the employer.

o  For certain types of contributions under a TSA contract to be
   excluded from taxable income, the employer must comply with
   certain nondiscrimination requirements.
   
Changing ownership

The contract and related certificates cannot be sold, assigned,
transferred, discounted or pledged as collateral for a loan or as
security for the performance of an obligation or for any other 
purpose to any person other than IDS Life of New York.  Your vested
rights under the certificate are nonforfeitable.
    
Benefits in case of death

If you die before annuity payouts begin, we will pay your
beneficiary as follows:

If death occurs before your 75th birthday, the beneficiary receives
the greater of:
o  the certificate value; or
o  purchase payments made to the certificate, minus any surrenders.

If death occurs on or after your 75th birthday, the beneficiary
receives the certificate value.

If your spouse is sole beneficiary and you die before the
retirement date, your spouse may keep the certificate in force.  To
do this your spouse must, within 60 days after we receive proof of
death, give us written instructions to keep the certificate in
force.  If you die before reaching age 70 1/2, your spouse may keep
the certificate in force until the date on which you would have
reached age 70 1/2.  

Payments:  We will pay the beneficiary in a single sum unless you
have given us other written instructions, or the beneficiary may
receive payouts under any annuity payout plan available under this
contract if:

o  the beneficiary asks us in writing within 60 days after we
   receive proof of death;
o  payouts begin no later than one year after death; and
o  the payout period does not extend beyond the beneficiary's life
   or life expectancy.

When paying the beneficiary, we will determine the certificate's
value at the next close of business after our death claim
requirements are fulfilled.  Interest, if any, will be paid from 
<PAGE>
PAGE 24
the date of death at a rate no less than required by law.  We will
mail payment to the beneficiary within seven days after our death
claim requirements are fulfilled. (See "Taxes.")

The annuity payout period

As the participant, you have the right to decide how and to whom
annuity payouts will be made starting at the retirement date.  You
may select one of the annuity payout plans outlined below, or we 
will mutually agree on other payout arrangements.  The amount
available for payouts under the plan you select is the certificate
value on the retirement date.  No surrender charges are deducted
under the payout plans listed below.

The contract and related certificates allow you to determine
whether payouts are to be made on a fixed or variable basis, or a
combination of fixed and variable.  Amounts of fixed and variable
payouts depend on:
o  the annuity payout plan you select;
o  your age;
o  the annuity table in the contract and related certificates;
o  the amounts allocated to the account(s) at settlement on the
   retirement date.

In addition, for variable payouts only, amounts depend on:
o  the investment performance of the account(s) selected.  
These payouts will vary from month to month because the performance
of the underlying mutual funds will fluctuate.  (In the case of
fixed annuities, payouts remain the same from month to month.)

Annuity payout plans
   
You may choose any one of these annuity payout plans by giving us
written instructions at least 30 days before certificate values are
to be used to purchase the payout plan.
    
o Plan A - Life annuity - no refund:  Monthly payouts are made
until the annuitant's death.  Payouts end with the last payout
before the annuitant's death; no further payouts will be made. 
This means that if the annuitant dies after only one monthly payout
has been made, no more payouts will be made.

o Plan B - Life annuity with five, 10 or 15 years certain:  Monthly
payouts are made for a guaranteed payout period of five, 10 or 15
years that the annuitant elects.  This election will determine the
length of the payout period to the beneficiary if the annuitant
should die before the elected period has expired.  The guaranteed 
payout period is calculated from the retirement date.  If the
annuitant outlives the elected guaranteed payout period, payouts
will continue until the annuitant's death.

o Plan C - Life annuity - installment refund:  Monthly payouts are
made until the annuitant's death, with our guarantee that payouts
will continue for some period of time.  Payouts will be made for at
<PAGE>
PAGE 25
least the number of months determined by dividing the amount
applied under this option by the first monthly payout, whether or
not the annuitant is living.

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

o Plan E - Payouts for a specified period (available as a fixed
payout only):  Monthly payouts are made for a specific payout
period of 10 to 30 years chosen by the annuitant.  Payouts will be
made only for the number of years specified whether the annuitant 
is living or not.  Depending on the time period selected, it is
foreseeable that an annuitant can outlive the payout period
selected.  In addition, a 10% IRS penalty tax could apply under
this payout plan.  (See "Taxes".)

Restrictions on payout options:  Because the certificate was
purchased under the plan, you must select a payout plan that
provides for payouts:

o  over the life of the annuitant;
o  over the joint lives of the annuitant and a designated
   beneficiary;
o  for a period not exceeding the life expectancy of the
   annuitant; or
o  for a period not exceeding the joint life expectancies
   of the annuitant and a designated beneficiary.
   
If we do not receive instructions:  You must give us written
instructions for the annuity payouts at least 30 days before your
retirement date.  If you do not, we will make payouts under Plan B,
with 120 monthly payouts guaranteed, unless this option is contrary
to applicable provisions of the plan or the Code.

If monthly payouts would be less than $20:  We will calculate the
amount of monthly payouts at the time the certificate value is used
to purchase a payout plan.  If the calculations show that monthly
payouts would be less than $20, we have the right to pay the
certificate value to the  participant in a lump sum.
    
Death after annuity payouts begin  
If the annuitant dies after annuity payouts begin, any amount
payable to the beneficiary will be as provided in the annuity
payout plan in effect.
   
Transfers between accounts after annuity payouts begin
After the annuity payouts begin, as the annuitant, you may transfer
the value of the annuity from one variable account to another once
each year.  You must send us written instructions to do this.  We
will make the transfer at the next close of business after we
receive your instructions.
    
<PAGE>
PAGE 26
Taxes

Generally, under current law, any increase in your certificate
value is taxable when you receive a payout or surrender except to
the extent that contributions were made with after-tax dollars.  
(See detailed discussion below.)  Any portion of the annuity
payouts and any surrenders requested that represent ordinary income
are normally taxable.  You will receive a 1099 tax information form
for any year in which a taxable distribution was made.

Annuity payouts:  The entire payout generally will be includable as
ordinary income and subject to tax.  If you or your employer
invested in the certificate with pre-tax dollars, such amounts are
not considered to be part of your investment in the certificate and
will be taxed when paid to you.

Surrenders:  Generally, if you surrender part or all of the
certificate before annuity payouts begin, the surrender payment
will be taxed.  You also may have to pay a 10% IRS penalty for
surrenders before reaching age 59 1/2.  Other penalties may apply
if you surrender the certificate before the plan specifies that you
can receive payouts.

Death benefits to beneficiaries:  The death benefit under an
annuity is not tax exempt.  Any amount received by the beneficiary
that represents previously deferred earnings within the
certificate, is taxable as ordinary income to the beneficiary in
the year(s) he or she receives the payments.

Penalties:  If you receive amounts from the certificate before
reaching age 59 1/2, you may have to pay a 10% IRS penalty on the
amount includable in your ordinary income.  However, this penalty
will not apply to any amount received by you or your beneficiary:

o  because of your death;
o  because you become disabled (as defined in the Code);
o  if the distribution is part of a series of substantially equal
   periodic payments, made at least annually, over your life or
   life expectancy (or joint lives or life expectancies of you and
   your designated beneficiary); or
o  after you separate from service in the year you attain age 55.

Other penalties or exceptions may apply if you surrender your 
certificate before your plan specifies that payments can be made.

Mandatory withholding:  If you receive directly all or part of the
certificate value, mandatory 20% income tax withholding generally
will be imposed at the time the payment is made.  Any withholding
that is done represents a prepayment of your tax due for the year
and you would take credit for such amounts on the annual tax return
you file.  This mandatory withholding will not be imposed if: 
o  instead of receiving the distribution check, you elect to have
   the distribution rolled over directly to an IRA or another
   eligible plan;
<PAGE>
PAGE 27
o  the payment is one in a series of substantially equal periodic
   payments, made at least annually, over your life or life
   expectancy (or the joint lives or life expectancies of you and
   your designated beneficiary) or over a specified period of 10
   years or more; or
o  the payment is a minimum distribution required under the Code.

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

Elective withholding:  If the distribution is not subject to 
mandatory withholding as described above, you can elect not to have
any withholding occur.  To do this you must provide us with a valid
Social Security Number or Taxpayer Identification Number.

If you do not make this election and if the payout is part of an
annuity payout plan, the amount of withholding generally is
computed using payroll tables.  You can provide us with a statement 
of how many exemptions to use in calculating the withholding.  If
the distribution is any other type of payment (such as a partial or
full surrender), withholding is computed using 10% of the taxable
portion.  

Some states also impose withholding requirements similar to the
federal withholding described above. If this should be the case,
any payments from which federal withholding is deducted may also
have state witholding deducted.  The withholding requirements may
differ if payment is being made to a non-U.S. citizen or if the
payment is being delivered outside the United States.

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

Tax Qualification

The contract and your certificate of participation thereunder is
intended to qualify as an annuity contract for Federal income tax
purposes.  To that end, the provisions of this contract and your
certificate are to be interpreted to ensure or maintain such tax
qualification, notwithstanding any other provisions to the
contrary.  We reserve the right to amend this contract and/or
related certificates to reflect any clarifications that may be 
needed or are appropriate to maintain such qualification or to
conform this contract to any applicable changes in the tax
qualification requirements.  We will send you a copy of any such
amendment.

<PAGE>
PAGE 28
Voting rights
   
As an owner or participant with investments in the variable
account(s) you may vote on important mutual fund policies until
annuity payouts begin.  Once they begin, the person receiving them
has voting rights.  We will vote fund shares according to the
instructions of the person with voting rights.
    
Before annuity payouts begin, the number of votes is determined by
applying the percentage interest in each variable account to the
total number of votes allowed to the account.

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

o  the reserve held in each account for the contract or
   certificate, divided by

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

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

We calculate votes separately for each account not more than 60
days before a shareholders' meeting.  Notice of these meetings,
proxy materials and a statement of the number of votes to which the
voter is entitled, will be sent.

We will vote shares for which we have not received instructions in
the same proportion as the votes for which we have received
instructions.  We also will vote the shares for which we have
voting rights in the same proportion as the votes for which we have
received instructions.

Substitution

Shares of any of the underlying funds may not always be available
for purchase by the variable accounts, or we may decide that
further investment in any such fund's shares is no longer
appropriate in view of the purposes of the variable account.  In
either event, shares of another registered open-end management
investment company may be substituted both for fund shares already
purchased by the variable account and for purchases to be made in
the future.  In the event of any substitution pursuant to this
provision, we may make appropriate endorsement to the contract and
certificates to reflect the substitution.

We reserve the right to split or combine the value of accumulation
units.  In effecting such change of unit values, strict equity will
be preserved and no change will have a material effect on the
benefits under the certificates or on any other provisions of the
contract and related certificates.

<PAGE>
PAGE 29
   
Distribution of the certificates

American Express Financial Advisors, Inc., a registered
broker/dealer and an affiliate of IDS Life of New York is the sole
distributor of the certificates.  IDS Life of New York pays total
commissions of up to 7.0% of the total purchase payments received
on the certificates.  A portion of this total commission is paid to
district and division sales managers of the selling representative.

About IDS Life of New York

The Employee Benefit Annuity is issued by IDS Life of New York, a
wholly owned subsidiary of IDS Life, which is a wholly owned
subsidiary of American Express Financial Corporation, which itself
is a wholly owned subsidiary of the American Express Company. 
American Express Company is a financial services company
principally engaged through subsidiaries (in addition to American
Express Financial Corporation) in travel related services,
investment services and international banking services.

IDS Life of New York is a stock life insurance company organized in
1972 under the laws of the State of New York and located at 20
Madison Avenue Extension, Albany, NY.  IDS Life of New York is
licensed in New York and North Dakota and conducts a conventional
life insurance business in the state of New York.

American Express Financial Advisors, Inc. offers mutual funds,
investment certificates and a broad range of financial management
services.  IDS Life of New York offers insurance and annuities.

American Express Financial Services, Inc. serves individuals and
businesses through its nationwide network of more than ___ offices
and more than ____ financial advisors.
    
Other subsidiaries provide investment management and related
services for pension, profit-sharing, employee savings and
endowment funds of businesses and institutions.

Regular and special reports

Services
To help you track and evaluate the performance of your annuity, we
provide:

Quarterly statements showing the value of your investment.

Annual reports containing required information on the annuity and
its underlying investments.
   
A personalized annuity progress report detailing the cumulative
return since the certificate was purchased and the average annual
rate of return on the investments.  This report, which is unique in
the industry, is available upon request from your financial
advisor.
    
<PAGE>
PAGE 30
Table of contents of the Statement of Additional Information

Performance information............................ 
Calculating annuity payouts........................ 
Rating agencies.................................... 
Principal underwriter.............................. 
Independent auditors...............................
Morality and expense risk charge................... 
Prospectus......................................... 
Financial statements -
      IDS Life of New York Accounts
      4, 5, 6, 9, 10 and 11........................ 
      IDS Life Insurance Company of New York....... 

___________________________________________________________________
Please check the appropriate box to receive a copy of the Statement
of Additional Information for:
   
_____ IDS Life of New York Employee Benefit Annuity

_____ IDS Life Retirement Annuity Mutual Funds

Please return this request to:

IDS Life of New York Annuity Service
IDS Life Insurance Company of New York
P.O. Box 5144
Albany, NY 12205
    
Your name _______________________________________________________

Address _________________________________________________________

City ______________________  State ______________ Zip ___________
<PAGE>
PAGE 31
















                STATEMENT OF ADDITIONAL INFORMATION

                                for

                     EMPLOYEE BENEFIT ANNUITY

        IDS LIFE OF NEW YORK ACCOUNTS 4, 5, 6, 9, 10 AND 11
   
                            May 1, 1995
    

IDS Life of New York Accounts 4, 5, 6, 9, 10 and 11 are separate
accounts established and maintained by IDS Life Insurance Company
of New York (IDS Life of New York).
   
This Statement of Additional Information, dated May 1, 1995, is not
a prospectus.  It should be read together with the accounts'
prospectus, dated May 1, 1995, which may be obtained from your 
financial advisor, or by writing or calling IDS Life of New York
Annuity Service at the address or telephone number below.
    


IDS Life of New York Annuity Service
20 Madison Avenue Extension
Albany, NY 12203
(518) 869-8613
<PAGE>
PAGE 32
                         TABLE OF CONTENTS

Performance Information.......................................p. 
   
Calculating Annuity Payouts...................................p. 
    
Rating Agencies...............................................p. 

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

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

Mortality and Expense Risk Charge.............................p. 

Prospectus....................................................p. 

Financial Statements 
          - IDS Life of New York Accounts 4, 5, 6, 9, 10 
            and 11............................................p. 
          - IDS Life Insurance Company of New York............p. 
<PAGE>
PAGE 33
PERFORMANCE INFORMATION

Calculation of yield for Account 6

IDS Life of New York Account 6, which invests in IDS Life
Moneyshare Fund, Inc., calculates an annualized simple yield and
compound yield based on a seven-day period.

The simple yield is calculated by determining the net change in the
value of a hypothetical account having the balance of one
accumulation unit at the beginning of the seven-day period.  (The
net change does not include capital change, but does include a pro
rata share of the annual contract charges, including the annual
contract administrative charge and the mortality and expense risk
fee.)  The net change in the account value is divided by the value
of the account at the beginning of the period to obtain the return
for the period.  That return is then multiplied by 365/7 to obtain
an annualized figure.  The value of the hypothetical account
includes the amount of any declared dividends, the value of any
shares purchased with any dividend paid during the period and any
dividends declared for such shares.  The variable account's
(account) yield does not include any realized or unrealized gains
or losses, nor does it include the effect of any applicable
surrender charge.

The account calculates its compound yield according to the
following formula:

                                                  365/7
Compound Yield = [(return for seven-day period +1)     ] - 1
   
On Dec. 31, 1994, the account's annualized yield was 4.23% percent
and its compound yield was 4.32% percent.
    
The rate of return, or yield, on the account's accumulation unit
may fluctuate daily and does not provide a basis for determining
future yields.  Investors must consider, when comparing an
investment in Account 6 with fixed annuities, that fixed annuities
often provide an agreed-to or guaranteed fixed yield for a stated
period of time, whereas the account's yield fluctuates.  In
comparing the yield of Account 6 to a money market fund, you should
consider the different services that the annuity provides.
   
Calculation of yield for Account 5

IDS Life of New York Account 5 invests in IDS Life Special Income
Fund, Inc.  Quotations of yield will be based on all investment
income earned during a particular 30-day period, less expenses
accrued during the period (net investment income) and will be
computed by dividing net investment income per accumulation unit by
the value of an accumulation unit on the last day of the period,
according to the following formula:
    
                         YIELD = 2[(a-b + 1)6 - 1]
                                     cd
<PAGE>
PAGE 34
where:    a = dividends and investment income earned during the
              period.
          b = expenses accrued for the period (net of
              reimbursements).
          c = the average daily number of accumulation units
              outstanding during the period that were entitled to
              receive dividends.
          d = the maximum offering price per accumulation unit on
              the last day of the period.

Yield on the account is earned from the increase in the net asset
value of shares of the fund in which the account invests and from
dividends declared and paid by the fund, which are automatically
invested in shares of the fund.
   
On Dec. 31, 1994, the account's annualized yield was ____%.
    
Calculation of average annual total return 

Quotations of average annual total return for an account will be
expressed in terms of the average annual compounded rate of return
of a hypothetical investment in the annuity contract over a period
of one, five and 10 years (or, if less, up to the life of the
Account), calculated according to the following formula:

                         P(1+T)n = ERV

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

Account total return figures reflect the deduction of the contract
administrative charge and mortality and expense risk fee. 
Performance figures will be shown with and may be shown without the
deduction of a surrender charge.  The Securities and Exchange
Commission requires that an assumption be made that the contract
owner surrenders the entire contract at the end of the one, five
and ten year periods (or, if less, up to the life of the account)
for which performance is required to be calculated.

Aggregate total return
   
Aggregate total return represents the cumulative change in the
value of an investment for a specified period of time (reflecting
change in an account's accumulation unit value) and is computed by
the following formula:
    
                               ERV - P
                                  P
<PAGE>
PAGE 35
where:       P = a hypothetical initial payment of $1,000.
           ERV = Ending Redeemable Value of a hypothetical $1,000
                 payment made at the beginning of the one, five, or
                 ten year (or other) period at the end of the one,
                 five, or ten year (or other) period (or fractional
                 portion thereof).
   
The following performance figures are calculated on the basis of
historical performance of the funds.

      Average Annual Total Return Period Ended: Dec. 31, 1994
<TABLE>
<CAPTION>
Average Annual Total Return with Surrender

                                                                                            Since
Account investing in:                        1 Year     3 Year     5 Year     10 Year     Inception
<S>                                          <C>        <C>        <C>        <C>         <C>
IDS LIFE
  Aggressive Growth Fund (1/92)*             
  Capital Resource Fund (10/81)              
  International Equity Fund (1/92)           
  Managed Fund (4/86)                        
  Moneyshare Fund (10/81)                    
  Special Income Fund (10/81)                

Average Annual Total Return without Surrender

                                                                                            Since
Account Investing in:                        1 Year     3 Year     5 Year     10 Year     Inception

IDS Life
  Aggressive Growth Fund (1/92)              
  Capital Resource Fund (10/81)              
  International Equity Fund (1/92)           
  Managed Fund (4/86)                        
  Moneyshare Fund (10/81)                    
  Special Income Fund (10/81)                

                        Aggregate Total Return Period Ended Dec. 31, 1994

Aggregate Total Return

                                                                                            Since
Account Investing in:                        1 Year     3 Year     5 Year     10 Year     Inception

IDS Life
  Aggressive Growth Fund (1/92)*             
  Capital Resource Fund (10/81)              
  International Equity Fund (1/92)           
  Managed Fund (4/86)                        
  Moneyshare Fund (10/81)                    
  Special Income Fund (10/81)                

*inception dates of the funds are shown in parentheses.
</TABLE>
    
Performance of the accounts may be quoted or compared to rankings,
yields, or returns as published or prepared by independent rating
or statistical services or publishers or publications such as The
Bank Rate Monitor National Index, Barron's, Business Week,
Donoghue's Money Market Fund Report, Financial Services Week,
Financial Times, Financial World, Forbes, Fortune, Global Investor,
Institutional Investor, Investor's Daily, Kiplinger's Personal
Finance, Lipper Analytical Services, Money, Mutual Fund Forecaster,
Newsweek, The New York Times, Personal Investor, Stanger Report,
Sylvia Porter's Personal Finance, USA Today, U.S. News and World
Report, The Wall Street Journal and Wiesenberger Investment
Companies Service. 
<PAGE>
PAGE 36
   
CALCULATING ANNUITY PAYOUTS

The Variable Account

The following calculations are done separately for each of the
variable accounts.  The separate monthly payouts, added together,
make up your total variable annuity payout.

Initial Payout:  To compute your first monthly payment, we:
o  determine the dollar value of your certificate as of the
valuation date seven days before the retirement date and then
deduct any applicable premium tax.

o  apply the result to the annuity table contained in the
certificate or another table at least as favorable.  The annuity
table shows the amount of the first monthly payment for each $1,000
of value which depends on factors built into the table, as
described below.

Annuity Units:  The value of your account is then converted to
annuity units.  To compute the number credited to you, we divide
the first monthly payment by the annuity unit value (see below) on
the valuation date on (or next day preceding) the seventh calendar
day before the retirement date.  The number of units in your
account is fixed.  The value of the units fluctuate with the
performance of the underlying mutual fund.

Subsequent Payouts:  To compute later payouts, we multiply:
o  the annuity unit value on the valuation date on or immediately
preceding the seventh calendar day before the payout is due; by
o  the fixed number of annuity units credited to you.

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

Annuity Unit Values:  This value was originally set at $1 for each
variable account.  To calculate later values we multiply the last
annuity value by the product of:
o  the net investment factor; and
o  the neutralizing factor.  The purpose of the neutralizing factor
is to offset the effect of the assumed investment rate built into
the annuity table.  With an assumed investment rate of 3.5%, the
neutralizing factor is 0.999906 for a one day valuation period.

Net Investment Factor:
o  Determined each business day by adding the underlying mutual
fund's current net asset value per share plus per share amount of
any current dividend or capital gain distribution; then
o  dividing that sum by the previous net asset value per share; and
o  subtracting the percentage factor representing the mortality and
expense risk fee from the result.
    <PAGE>
PAGE 37
   
Because the net asset value of the underlying mutual fund may
fluctuate, the net investment factor may be greater or less than
one, and the accumulation unit value may increase or decrease.  You
bear this investment risk in a variable account.

The Fixed Account

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

o  take the value of your fixed account at the retirement date or
the date you have selected to begin receiving your annuity payouts;
then
o  using an annuity table we apply the value according to the
annuity payout plan you select; and
o  the annuity payout table we use will be the one in effect at the
time you choose to begin your annuity payouts.  The table will be
equal to or greater than the table in your certificate.

RATING AGENCIES

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

Rating agency            Rating

A.M. Best                  A+
                       (Superior)

Duff & Phelps             AAA

Moody's                   Aa2

PRINCIPAL UNDERWRITER

The principal underwriter for the accounts is American Express
Financial Advisors Inc. which offers the variable annuities on a
continuous basis.

Surrender charges received by IDS Life of New York for 1994, 1993,
and 1992, aggregated $269,275, $151,536, and $136,471,
respectively.  Commissions paid by IDS Life of New York for 1994,
1993, and 1992, aggregated $________________, $1,244,668, and
$631,691, respectively.  The surrender charges were applied toward
payment of commissions.
    
<PAGE>
PAGE 38
INDEPENDENT AUDITORS

Ernst & Young, 1400 Pillsbury Center, Minneapolis, MN 55402, are
the independent auditors of the financial statements of IDS Life of
New York and the Separate Accounts.

MORTALITY AND EXPENSE RISK CHARGE

IDS Life of New York has represented to the SEC that:

IDS Life of New York has reviewed publicly available information
regarding products of other companies.  Based upon this review, IDS
Life of New York has concluded that the mortality and expense risk
charge is within the range of charges determined by industry
practice.  IDS Life of New York will maintain at its principal
office, and make available on request of the SEC or its staff, a
memorandum setting forth in detail the variable products analyzed
and the methodology, and results of, its comparative review.

IDS Life of New York has concluded that there is a reasonable
likelihood that the proposed distribution financing arrangements
made with respect to the annuities will benefit the variable 
account and investors in the annuities.  The basis for such
conclusion is set forth in a memorandum which will be made
available to the SEC or its staff on request.

PROSPECTUS
   
The prospectus dated May 1, 1995, is hereby incorporated in this
Statement of Additional Information by reference.
    
<PAGE>
PAGE 39
PART C.

Item 24.    Financial Statements and Exhibits

(a)   To be filed by amendment.

(b)   Exhibits:

1.1   Resolution of the Executive Committee of the Board of
      Directors of IDS Life of New York establishing Accounts C, D,
      E, F, G, H dated November 12, 1981, filed electronically as
      Exhibit 1.1 to Registration Statement No. 33-52567, is
      incorporated herein by reference.

1.2   Resolution of the Executive Committee of the Board of
      Directors of IDS Life of New York establishing Account 9 on
      Feb. 12, 1986, filed electronically as Exhibit 1.2 to
      Registration Statement No. 33-52567, is incorporated herein
      by reference.

1.3   Resolution of the Board of Directors of IDS Life Insurance
      Company of New York establishing Accounts 10 and 11 on Oct.
      8, 1991, filed electronically as Exhibit 1.3 to Registration
      Statement No. 33-52567, is incorporated herein by reference.

2.    Not applicable.

3.    Form of Variable Annuity and Life Insurance Distribution
      Agreement filed electronically as Exhibit 3 to Registration
      Statement No. 33-52567, is incorporated herein by reference.

4.1   Copy of form of Group Deferred Annuity Contract (form 38607)
      filed electronically as Exhibit 4.1 to Registration Statement
      No. 33-52567, is incorporated herein by reference.

4.2   Copy of form of Group Deferred Annuity Participant
      Certificate (form 38611) filed electronically as Exhibit 4.2
      to Registration Statement No. 33-52567, is incorporated
      herein by reference.

5.1   Copy of form of Employee Benefit Annuity Master Application
      for Group Deferred Annuity Contract (form 38608 A), filed
      electronically herewith.

5.2   Copy of form of Participant Enrollment Form (for Employee
      Benefit Annuity) (form 38609 A), filed electronically
      herewith.

6.1   Copy of the Revised Charter of IDS Life of New York, dated
      April, 1992, filed electronically as Exhibit 6.1 to
      Registration Statement No. 33-52567, is incorporated herein
      by reference.

6.2   Copy of Amended By-Laws of IDS Life of New York, dated May,
      1992, filed electronically as Exhibit 6.2 to Registration
      Statement No. 33-52567, is incorporated herein by reference.

<PAGE>
PAGE 40
7.    Not applicable.

8.    Not applicable.

9.    Opinion of counsel and consent to its use as to the legality
      of the securities being registered will be filed with
      Registrant's 24f-2 Notice on or about February 28, 1995.

10.   To be filed by amendment.

11.   To be filed by amendment.

12.   Not applicable.

13.   Copy of schedule for computation of each performance
      quotation provided in the Registration Statement in response
      to Item 21, filed electronically as Exhibit 13 to Pre-
      Effective Amendment No. 1 to Registration Statement No. 33-
      52567, is incorporated herein by reference.

14.   N/A.

15.   Powers of Attorney to sign Amendments to this Registration
      Statement, dated April 18, 1994, filed electronically as
      Exhibit 14 to Pre-Effective Amendment No. 1 to Registration
      Statement No. 33-52567, is incorporated herein by reference.

<PAGE>
PAGE 41
Item 25.    Directors and Officers of the Depositor
<TABLE>
<CAPTION>
                                                        Positions and
Name                     Principal Business Address     Offices with Depositor
<S>                      <C>                            <C>
Mario Alaia              20 Madison Avenue Extension    Claims Officer and
                         Albany, NY                       Assistant Secretary

Tracy A. Anderson        IDS Tower 10                   Treasurer and Chief Actuary
                         Minneapolis, MN  55440

Darrell C. Beckstrom     IDS Tower 10                   Underwriting Officer
                         Minneapolis, MN  55440

John C. Boeder           20 Madison Avenue Extension    Director
                         Albany, NY

Michael B. Carlin                                       General Counsel and
                                                          Secretary

Roger C. Corea           20 Madison Avenue Extension    Director
                         Albany, NY

Charles A. Cuccinello    20 Madison Avenue Extension    Director
                         Albany, NY

Milton R. Fenster        20 Madison Avenue Extension    Director
                         Albany, NY

Margaret M. Grogan, M.D. Bethlehem Terrace Apts.        Medical Director
                         Slingerland, NY

Lorraine R. Hart         IDS Tower 10                   Investment Officer
                         Minneapolis, MN  55440

Robert A. Hatton                                        Vice President and
                                                          Chief Operating Officer

Richard W. Kling         IDS Tower 10                   Director, Chairman of
                         Minneapolis, MN  55440           the Board and President

Edward Landes            IDS Tower 10                   Director
                         Minneapolis, MN  55440

Janis E. Miller                                         Executive Vice President


Michael P. Monaco        World Financial Center         Director
                         New York, NY  

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

Kevin E. Palmer                                         Reinsurance Actuary


<PAGE>
PAGE 42
Louise M. Parent         World Financial Center         Director
                         New York, NY

Carl N. Platou                                          Director


Gordon H. Ritz           404 WCCO Radio Bldg.           Director
                         Minneapolis, MN 

F. Dale Simmons          IDS Tower 10                   Vice President and
                         Minneapolis, MN  55440           Assistant Treasurer

William A. Stoltzmann    IDS Tower 10                   Counsel and Assistant
                         Minneapolis, MN  55440           Secretary

Michael R. Woodward      20 Madison Avenue Extension    Director
                         Albany, NY
</TABLE>
<PAGE>
PAGE 43
Item 26.  Persons Controlled by or Under Common Control with the
          Depositor or Registrant

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

          The following list includes the names of major
          subsidiaries of American Express.  

                                                  Jurisdiction
Name of Subsidiary                                of Incorporation

I.   Travel Related Services

     American Express Travel Related 
     Services Company, Inc.                       New York

II.  International Banking Services

     American Express Bank Ltd.                   Connecticut

III. Investment Services

     Lehman Brothers Inc.                         Delaware

IV.  Companies engaged in Investors 
     Diversified Financial Services

     American Enterprise Investment Services Inc.   Minnesota
     American Enterprise Life Insurance Company     Indiana
     American Express Financial Corporation         Delaware
     American Express Financial Advisors Inc.       Delaware
     American Express Minnesota Foundation          Minnesota
     American Express Service Corporation           Delaware
     American Express Trust Company                 Minnesota
     American Partners Life Insurance Company       Arizona
     IDS Advisory Group Inc.                        Minnesota
     IDS Aircraft Services Corporation              Minnesota
     IDS Cable Corporation                          Minnesota
     IDS Cable II Corporation                       Minnesota
     IDS Capital Holdings Inc.                      Minnesota
     IDS Certificate Company                        Delaware
     IDS Deposit Corp.                              Utah
     IDS Fund Management Limited                    U.K.
     IDS Futures Corporation                        Minnesota
     IDS Futures III Corporation                    Minnesota
     IDS Insurance Agency of Alabama Inc.           Alabama
     IDS Insurance Agency of Arkansas Inc.          Arkansas
     IDS Insurance Agency of Massachusetts Inc.     Massachusetts
     IDS Insurance Agency of Mississippi Inc.       Mississippi
     IDS Insurance Agency of Nevada Inc.            Nevada
     IDS Insurance Agency of New Mexico Inc.        New Mexico
<PAGE>
PAGE 44
Item 26.  Persons Controlled by or Under Common Control with the
          Depositor or Registrant (Continued)

                                                  Jurisdiction
Name of Subsidiary                                of Incorporation

     IDS Insurance Agency of North Carolina Inc.    North Carolina
     IDS Insurance Agency of Ohio Inc.              Ohio
     IDS Insurance Agency of Texas Inc.             Texas
     IDS Insurance Agency of Utah Inc.              Utah
     IDS Insurance Agency of Wyoming Inc.           Wyoming
     IDS International, Inc.                        Delaware
     IDS Life Insurance Company                     Minnesota
     IDS Life Insurance Company of New York         New York
     IDS Management Corporation                     Minnesota
     IDS Partnership Services Corporation           Minnesota
     IDS Plan Services of California, Inc.          Minnesota
     IDS Property Casualty Insurance Company        Wisconsin
     IDS Real Estate Services, Inc.                 Delaware
     IDS Realty Corporation                         Minnesota
     IDS Sales Support Inc.                         Minnesota
     IDS Securities Corporation                     Delaware
     Investors Syndicate Development Corp.          Nevada

Item 27.  Number of Contractowners

          Not applicable.

Item 28.  Indemnification

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

Insofar as indemnification for liability arising under the
Securities Act of 1933 may be permitted to director, officers and
controlling persons of the registrant pursuant to the foregoing
provisions, or otherwise, the registrant has been advised that in
the opinion of the Securities and Exchange Commission such
indemnification is against public policy as expressed in the Act 
<PAGE>
PAGE 45
and is, therefore, unenforceable.  In the event that a claim for
indemnification against such liabilities (other than the payment by
the registrant of expenses incurred or paid by a director, officer
or controlling person of the registrant in the successful defense
of any action, suit or proceeding) is asserted by such director,
officer or controlling person in connection with the securities
being registered, the registrant will, unless in the opinion of its
counsel the matter has been settled by controlling precedent,
submit to a court of appropriate jurisdiction the question whether
such indemnification by it is against public policy as expressed in
the Act and will be governed by the final adjudication of such
issue.

Item 29.     Principal Underwriters.

(a)  American Expess Financial Advisors Inc. (formerly IDS
     Financial Services Inc.) acts as principal underwriter
     for the following investment companies:

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

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

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant   

Ronald G. Abrahamson     Vice President-              None
IDS Tower 10             Service Quality and 
Minneapolis, MN 55440    Reengineering

Douglas A. Alger         Vice President-Total         None
IDS Tower 10             Compensation
Minneapolis, MN 55440

Jerome R. Amundson       Vice President-              None
IDS Tower 10             Investment Accounting
Minneapolis, MN 55440

Peter J. Anderson        Senior Vice President-       None
IDS Tower 10             Investments
Minneapolis, MN 55440

<PAGE>
PAGE 46
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant   

Ward D. Armstrong        Vice President-              None
IDS Tower 10             Sales and Marketing,
Minneapolis, MN  55440   American Express 
                         Institutional Services

Alvan D. Arthur          Group Vice President-        None
IDS Tower 10             Central California/Western
Minneapolis, MN  55440   Nevada

Kent L. Ashton           Vice President-              None
IDS Tower 10             Financial Education
Minneapolis, MN 55440    Services
Joseph M. Barsky III     Vice President-Senior        None
IDS Tower 10             Portfolio Manager
Minneapolis, MN  55440

Robert C. Basten         Vice President-Tax           None
IDS Tower 10             and Business Services
Minneapolis, MN  55440

Timothy V. Bechtold      Vice President-Insurance     None
IDS Tower 10             Product Development
Minneapolis, MN  55440

John D. Begley           Group Vice President-        None
Olentangy Valley Center  Ohio/Indiana
Suite 300
7870 Olentangy River Rd.
Columbus, OH  43235

Carl E. Beihl            Vice President-              None
IDS Tower 10             Strategic Technology
Minneapolis, MN 55440    Planning

Jack A. Benjamin         Group Vice President-        None
                         Greater Pennsylvania

Alan F. Bignall          Vice President-              None
IDS Tower 10             Financial Planning
Minneapolis, MN 55440    Systems

Brent L. Bisson          Group Vice President-        None
Seafirst Financial       Los Angeles Metro
Center, Suite 1730
601 W. Riverside Ave.
Spokane, WA 99201

John C. Boeder           Vice President-              None
IDS Tower 10             Mature Market Group
Minneapolis, MN  55440
<PAGE>
PAGE 47
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant   

Bruce J. Bordelon        Group Vice President-        None
                         Gulf States

Charles R. Branch        Group Vice President-        None
                         Northwest

Karl J. Breyer           Senior Vice President-       None
IDS Tower 10             Corporate Affairs and
Minneapolis, MN 55440    Special Counsel

Harold E. Burke          Vice President               None
IDS Tower 10             and Assistant 
Minneapolis, MN 55440    General Counsel

Daniel J. Candura        Vice President-              None
IDS Tower 10             Marketing Support
Minneapolis, MN  55440

Cynthia M. Carlson       Vice President-              None
IDS Tower 10             American Express
Minneapolis, MN  55440   Securities Services

Orison Y. Chaffee III    Vice President-Field         None
IDS Tower 10             Real Estate
Minneapolis, MN 55440

James E. Choat           Senior Vice President-       None
Suite 124                Field Management
6210 Campbell Rd.
Dallas, TX 75248

Kenneth J. Ciak          Vice President and           None
IDS Property Casualty    General Manager-
1400 Lombardi Avenue     IDS Property Casualty
Green Bay, WI 54304

Roger C. Corea           Group Vice President-        None
345 Woodcliff Drive      Upstate New York
Fairport, NY  14450

Henry J. Cormier         Group Vice President-        None
                         Connecticut

John M. Crawford         Group Vice President-        None
                         Arkansas/Springfield/Memphis

Kevin F. Crowe           Group Vice President-        None
IDS Tower 10             Carolinas/Eastern Georgia
Minneapolis, MN 55440    
<PAGE>
PAGE 48
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant   

Alan R. Dakay            Vice President-              None
IDS Tower 10             Institutional Insurance
Minneapolis, MN 55440    Marketing

Regenia David            Vice President-              None
                         Systems Services

Scott M. Digiammarino    Group Vice President-        None
                         Washington/Baltimore

Bradford L. Drew         Group Vice President-        None
                         Eastern Florida

William H. Dudley        Director and Executive       Director/
IDS Tower 10             Vice President-              Trustee
Minneapolis MN 55440     Investment Operations

Roger S. Edgar           Senior Vice President-       None
IDS Tower 10             Information Systems
Minneapolis, MN 55440

Gordon L. Eid            Senior Vice President        None
IDS Tower 10             and General Counsel
Minneapolis, MN 55440

Robert M. Elconin        Vice President-              None
IDS Tower 10             Government Relations
Minneapolis, MN  55440

Mark A. Ernst            Vice President-              None
IDS Tower 10             Retail Services
Minneapolis, MN 55440

Joseph Evanovich Jr.     Group Vice President-        None
                         Nebraska/Iowa/Dakotas

Louise P. Evenson        Group Vice President-        None
                         San Francisco Bay Area

Gordon M. Fines          Vice President-              None
IDS Tower 10             Mutual Fund Equity
Minneapolis MN 55440     Investments

Louis C. Fornetti        Senior Vice President        None
IDS Tower 10             and Chief Financial
Minneapolis, MN 55440    Officer

Douglas L. Forsberg      Group Vice President-        None
IDS Tower 10             Portland/Eugene
Minneapolis, MN 55440
<PAGE>
PAGE 49
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant   

William P. Fritz         Group Vice President-        None
                         Northern Missouri

Carl W. Gans             Group Vice President-        None
IDS Tower 10             Twin City Metro
Minneapolis, MN  55440

Bruce M. Gaurino         Group Vice President-        None
                         Hawaii

Robert G. Gilbert        Vice President-              None
IDS Tower 10             Real Estate
Minneapolis, MN 55440

John J. Golden           Vice President-              None
IDS Tower 10             Field Compensation
Minneapolis, MN  55440   Development

Morris Goodwin Jr.       Vice President and           None
IDS Tower 10             Corporate Treasurer
Minneapolis, MN 55440

Suzanne Graf             Vice President-              None
IDS Tower 10             Systems Services
Minneapolis, MN  55440

Bruce M. Guarino         Group Vice President-        None
                         Hawaii

David A. Hammer          Vice President               None
IDS Tower 10             and Marketing
Minneapolis, MN  55440   Controller

Teresa A. Hanratty       Group Vice President-        None
                         Northern New England

John R. Hantz            Group Vice President-        None
                         Detroit Metro

Robert L. Harden         Group Vice President-        None
Suite 403                Boston Metro
8500 Leesburg Pike
Vienna, VA  22180

Lorraine R. Hart         Vice President-              None
IDS Tower 10             Insurance Investments
Minneapolis, MN 55440

Scott A. Hawkinson       Vice President-Assured       None
IDS Tower 10             Assets Product Development
Minneapolis, MN 55440    and Management
<PAGE>
PAGE 50
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant   

Brian M. Heath           Group Vice President-        None
IDS Tower 10             North Texas
Minneapolis, MN  55440

Raymond E. Hirsch        Vice President-Senior        None
IDS Tower 10             Portfolio Manager
Minneapolis, MN 55440

James G. Hirsh           Vice President and           None
IDS Tower 10             Assistant General
Minneapolis, MN  55440   Counsel

David J. Hockenberry     Group Vice President-        None
                         Eastern Tennessee

Kevin P. Howe            Vice President-              None
IDS Tower 10             Government and
Minneapolis, MN  55440   Customer Relations

David R. Hubers          Chairman, Chief              None
IDS Tower 10             Executive Officer and
Minneapolis, MN 55440    President

Marietta L. Johns        Senior Vice President-       None
IDS Tower 10             Field Management
Minneapolis, MN 55440

Douglas R. Jordal        Vice President-Taxes         None
IDS Tower 10
Minneapolis, MN 55440

Craig A. Junkins         Vice President - IDS 1994    None
IDS Tower 10             Implementation Planning
Minneapolis, MN 55440    and Financial Planning
                         Development

James E. Kaarre          Vice President-              None
IDS Tower 10             Marketing Information
Minneapolis, MN  55440

Linda B. Keene           Vice President-              None
                         Market Development

G. Michael Kennedy       Vice President-Investment    None
IDS Tower 10             Services and Investment
Minneapolis, MN  55440   Research

Susan D. Kinder          Senior Vice President-       None
IDS Tower 10             Human Resources
Minneapolis, MN 55440
<PAGE>
PAGE 51
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant   

Richard W. Kling         Senior Vice President-       None
IDS Tower 10             Risk Management Products
Minneapolis, MN  55440

Harold D. Knutson        Vice President-              None
IDS Tower 10             System Services
Minneapolis, MN 55440

Paul F. Kolkman          Vice President-              None
IDS Tower 10             Actuarial Finance
Minneapolis, MN 55440

Claire Kolmodin          Vice President-              None
IDS Tower 10             Service Quality
Minneapolis, MN  55440

David S. Kreager         Group Vice President-        None
IDS Tower 10             Greater Michigan
Minneapolis, MN  55440

Steven C. Kumagai        Director and Senior          None
IDS Tower 10             Vice President-Field
Minneapolis, MN 55440    Management and Business
                         Systems

Mitre Kutanovski         Group Vice President-        None
IDS Tower 10             Chicago Metro
Minneapolis, MN  55440

Edward Labenski          Vice President-              None
IDS Tower 10             Senior Portfolio
Minneapolis, MN 55440    Manager

Kurt A. Larson           Vice President-              None
IDS Tower 10             Senior Portfolio
Minneapolis, MN  55440   Manager

Lori J. Larson           Vice President-              None
IDS Tower 10             Variable Assets Product
Minneapolis, MN  55440   Development

Ryan R. Larson           Vice President-              None
IDS Tower 10             IPG Product Development
Minneapolis, MN 55440

Daniel E. Laufenberg     Vice President and           None
IDS Tower 10             Chief U.S. Economist
Minneapolis, MN  55440
<PAGE>
PAGE 52
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant   

Richard J. Lazarchic     Vice President-              None
IDS Tower 10             Senior Portfolio 
Minneapolis, MN  55440   Manager

Peter A. Lefferts        Senior Vice President and    None
IDS Tower 10             Chief Marketing Officer
Minneapolis, MN  55440

Douglas A. Lennick       Director and Executive       None
IDS Tower 10             Vice President-Private
Minneapolis, MN  55440   Client Group

Mary J. Malevich         Vice President-              None
IDS Tower 10             Senior Portfolio
Minneapolis, MN 55440    Manager

Fred A. Mandell          Vice President-              None
IDS Tower 10             Field Marketing Readiness
Minneapolis, MN  55440

Daniel E. Martin         Group Vice President-        None
                         Pittsburgh Metro

William J. McKinney      Vice President-              None
IDS Tower 10             Field Management
Minneapolis, MN  55440   Support

Thomas W. Medcalf        Vice President-              None
IDS Tower 10             Senior Portfolio Manager
Minneapolis, MN 55440

William C. Melton        Vice President-              None
IDS Tower 10             International Research
Minneapolis, MN 55440    and Chief International 
                         Economist

Janis E. Miller          Vice President-              None
IDS Tower 10             Variable Assets
Minneapolis, MN 55440

James A. Mitchell        Executive Vice President-    None
IDS Tower 10             Marketing and Products
Minneapolis, MN 55440

John P. Moraites         Group Vice President-        None
                         Kansas/Oklahoma

Pamela J. Moret          Vice President-              None
IDS Tower 10             Corporate Communications
Minneapolis, MN 55440    
<PAGE>
PAGE 53
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant   

Barry J. Murphy          Senior Vice President-       None
IDS Tower 10             Client Service
Minneapolis, MN  55440

Robert J. Neis           Vice President-              None
IDS Tower 10             Information Systems
Minneapolis, MN 55440    Operations

Ronald E. Newton         Group Vice President-        None
                         Rhode Island/Central
                         Massachusetts

Thomas V. Nicolosi       Group Vice President-        None
                         New York Metro Area

Vernon F. Palen          Region Vice President-       None
Suite D-222              Rocky Mountain Region
7100 E. Lincoln Drive
Scottsdale, AZ  85253

James R. Palmer          Vice President-              None
IDS Tower 10             Insurance Operations
Minneapolis, MN 55440

Carla P. Pavone          Vice President-              None
IDS Tower 10             Specialty Service Teams
Minneapolis, MN  55440   and Emerging Business

Judith A. Pennington     Vice President-              None
IDS Tower 10             Field Technology
Minneapolis, MN  55440

George M. Perry          Vice President-              None
IDS Tower 10             Corporate Strategy
Minneapolis, MN 55440    and Development

Susan B. Plimpton        Vice President-              None
IDS Tower 10             Segmentation Development
Minneapolis, MN 55440    and Support

Larry M. Post            Group Vice President-        None
                         Philadelphia Metro

Ronald W. Powell         Vice President and           None
IDS Tower 10             Assistant General
Minneapolis, MN 55440    Counsel

James M. Punch           Vice President-              None
IDS Tower 10             TransAction Services
Minneapolis, MN 55440
<PAGE>
PAGE 54
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant   

Frederick C. Quirsfeld   Vice President-Taxable       None
IDS Tower 10             Mutual Fund Investments
Minneapolis, MN 55440

R. Daniel Richardson     Group Vice President-        None
                         Southern Texas

Roger B. Rogos           Group Vice President-        None
Suite 15, Parkside Pl.   Western Florida
945 Boardman-Canfield Rd
Youngstown, Ohio  44512

ReBecca K. Roloff        Vice President-1994          None 
IDS Tower 10             Program Director
Minneapolis, MN  55440   

Stephen W. Roszell       Vice President-              None
IDS Tower 10             Advisory Institutional
Minneapolis, MN  55440   Marketing

Max G. Roth              Group Vice President-        None
                         Wisconsin/Upper Michigan

Robert A. Rudell         Vice President-              None
IDS Tower 10             American Express    
Minneapolis, MN 55440    Institutional Services

John P. Ryan             Vice President and           None
IDS Tower 10             General Auditor
Minneapolis, MN 55440

Erven A. Samsel          Senior Vice President-       None
45 Braintree Hill Park   Field Management
Braintree, MA 02184

Russell L. Scalfano      Group Vice President-        None
                         Illinois/Indiana/Kentucky

William G. Scholz        Group Vice President-        None
                         Arizona/Las Vegas

Stuart A. Sedlacek       Vice President-              None
IDS Tower 10             Assured Assets
Minneapolis, MN  55440

Donald K. Shanks         Vice President-              None
IDS Tower 10             Property Casualty
Minneapolis, MN  55440
<PAGE>
PAGE 55
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant   

F. Dale Simmons          Vice President-Senior        None
IDS Tower 10             Portfolio Manager,
Minneapolis, MN 55440    Insurance Investments

Judy P. Skoglund         Vice President-              None
IDS Tower 10             Human Resources and
Minneapolis, MN  55440   Organization Development

Julian W. Sloter         Group Vice Presidnet-        None
9040 Roswell Rd.         Orlando/Jacksonville
River Ridge-Suite 600
Atlanta, GA  30350

Ben C. Smith             Vice President-              None
IDS Tower 10             Workplace Marketing
Minneapolis, MN  55440

William A. Smith         Vice President and           None
IDS Tower 10             Controller-Private
Minneapolis, MN 55440    Client Group

James B. Solberg         Group Vice President-        None
IDS Tower 10             Eastern Iowa Area
Minneapolis, MN 55440

Bridget Sperl            Vice President-              None
IDS Tower 10             Human Resources
Minneapolis, MN 55440    Management Services

Paul J. Stanislaw        Group Vice President-        None
                         Southern California

Lois A. Stilwell         Group Vice President-        None
IDS Tower 10             Outstate Minnesota Area/
Minneapolis, MN  55440   North Dakota/Western Wisconsin

William A. Stoltzmann    Vice President and           None
IDS Tower 10             Assistant General
Minneapolis, MN 55440    Counsel

James J. Strauss         Vice President-              None
IDS Tower 10             Corporate Planning
Minneapolis, MN 55440    and Analysis

Jeffrey J. Stremcha      Vice President-Information   None
IDS Tower 10             Resource Management/ISD
Minneapolis, MN  55440

Neil G. Taylor           Group Vice President-        None
IDS Tower 10             Seattle/Tacoma
Minneapolis, MN 55440
<PAGE>
PAGE 56
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant   

John R. Thomas           Senior Vice President-       Director/
IDS Tower 10             Information and              Trustee
Minneapolis, MN 55440    Technology

Melinda S. Urion         Vice President and           None
IDS Tower 10             Corporate Controller
Minneapolis, MN 55440

Peter S. Velardi         Group Vice President-        None
                         Atlanta/Birmingham

Charles F. Wachendorfer  Group Vice President-        None
                         Denver/Salt Lake City/
                         Albuquerque

Wesley W. Wadman         Vice President-              None
IDS Tower 10             Senior Portfolio
Minneapolis, MN 55440    Manager

Norman Weaver Jr.        Senior Vice President-       None
Suite 215                Field Management
1501 Westcliff Drive
Newport Beach, CA  92660

Michael L. Weiner        Vice President-              None
IDS Tower 10             Corporate Tax
Minneapolis, MN 55440    Operations

Lawrence J. Welte        Vice President-              None
IDS Tower 10             Investment Administration
Minneapolis, MN  55440

Jeffry M. Welter         Vice President-              None
IDS Tower 10             Equity and Fixed Income
Minneapolis, MN  55440   Trading

William N. Westhoff      Senior Vice President and    None
IDS Tower 10             Global Chief Investment
Minneapolis, MN  55440   Officer

Thomas L. White          Group Vice President-        None
                         Cleveland Metro

Eric S. Williams         Group Vice President-        None
                         Virginia

Edwin M. Wistrand        Vice President and           None
IDS Tower 10             Assistant General
Minneapolis, MN 55440    Counsel

<PAGE>
PAGE 57
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant   

Michael R. Woodward      Senior Vice President-       None
Suite 815                Field Management
8585 Broadway
Merrillville, IN  46410

<TABLE>
<CAPTION>
(c)  Name of           Net Underwriting
     Principal         Discounts and     Compensation on   Brokerage    Other
     Underwriter       Commissions       Redemption        Commissions  Compensation
     <S>                    <C>          <C>                   <C>          <C>
     American Express
     Financial Advisors
     Inc.                   None                               None         None
</TABLE>

Item 30.  Location of Accounts and Records

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

Item 31.  Management Services

          Not applicable.

Item 32.  Undertakings

(a) (b) & (c)  These undertakings were filed with the Registrant's
               initial Registration Statement, File No. 33-52567.

(d)            Registrant represents that it is relying upon the
               no-action assurance given to the American Council of
               Life Insurance (pub. avail. Nov. 28, 1988). 
               Further, Registrant represents that it has complied
               with the provisions of paragraphs (1)-(4) of that
               no-action letter.
<PAGE>
PAGE 58
                            SIGNATURES

As required by the Securities Act of 1933 and the Investment
Company Act of 1940, IDS Life Insurance Company of New York, on
behalf of the Registrant, certifies that it meets the requirements
for effectiveness of this Amendment to its Registration Statement
pursuant to Rule 486(b) under the Securities Act of 1933 and has
duly caused this Registration Statement to be signed on its behalf,
in the City of Minneapolis, and State of Minnesota, on the 24th day
of February, 1995.

                                  IDS LIFE ACCOUNT 4
                                  IDS LIFE ACCOUNT 5
                                  IDS LIFE ACCOUNT 6
                                  IDS LIFE ACCOUNT 9
                                  IDS LIFE ACCOUNT 10
                                  IDS LIFE ACCOUNT 11              
                                      (Registrant)

                          By IDS Life Insurance Company of New York
                                          (Sponsor)

                          By /s/ Richard W. Kling*                 
                                 Richard W. Kling
                                 President

As required by the Securities Act of 1933, this Registration
Statement has been signed by the following persons in the
capacities indicated on the 24th day of February, 1995.

Signature                               Title

/s/ Richard W. Kling*                   Director and President
    Richard W. Kling

/s/ John C. Boeder*                     Director 
    John C. Boeder

/s/ Roger C. Corea*                     Director
    Roger C. Corea

/s/ Charles A. Cuccinello*              Director
    Charles A. Cuccinello

/s/ Milton R. Fenster*                  Director
    Milton R. Fenster

/s/ Edward Landes*                      Director
    Edward Landes

/s/ Michael P. Monaco*                  Director
    Michael P. Monaco

/s/ Steven P. Norman*                   Director
    Steven P. Norman
<PAGE>
PAGE 59
Signature                               Title

/s/ Louise M. Parent*                   Director
    Louise M. Parent

/s/ Carl Platou*                        Director
    Carl Platou

/s/ Gordon H. Ritz*                     Director
    Gordon H. Ritz

/s/ Michael R. Woodward*                Director
    Michael R. Woodward


*Signed pursuant to Power of Attorney, dated April 18, 1994, filed
electronically as Exhibit 14 to Pre-Effective Amendment No. 1 to
Registration Statement No. 33-52567, is incorporated herein by
reference.



______________________________
Mary Ellyn Minenko 
<PAGE>
PAGE 60
            CONTENTS OF POST-EFFECTIVE AMENDMENT NO. 1

This Registration Statement is comprised of the following papers
and documents:

The Cover Page.

Cross-reference sheet.

Part A.

     The prospectus.

Part B.

     Statement of Additional Information.

Part C.

     Other Information.

     The signatures.

Exhibits.


<PAGE>
PAGE 1
IDS Life of New York Employee Benefit Annuity
Registration Number 33-52567/811-3500

                           EXHIBIT INDEX

Exhibit 5.1    Copy of form of Employee Benefit Annuity Master
               Application for Group Deferred Annuity Contract
               (form 38608 A).

Exhibit 5.2    Copy of form of Participant Enrollment Form (for
               Employee Benefit Annuity, form 38609 A).


<PAGE>
PAGE 1
GROUP DEFERRED ANNUITY CONTRACT


- - Employer Plan
- - Group Deferred Annuity - Individual Allocation
- - Optional fixed dollar or variable accumulation values and annuity
  payments.
- - This contract is nonparticipating. Dividends are not payable.



This is a deferred annuity contract. It is a legal contract between
you, as the owner, and us, IDS Life Insurance Company of New York,
a Stock Company, Albany, New York.  PLEASE READ YOUR CONTRACT
CAREFULLY.

We agree: to pay annuity benefits provided in this contract and; to
provide you and the Participants and Beneficiaries with the rights
and benefits contained in this contract. 



ACCUMULATION VALUES AND ANNUITY PAYMENTS, WHEN BASED ON THE
INVESTMENT RESULTS OF THE SEPARATE ACCOUNTS, ARE VARIABLE AND NOT
GUARANTEED AS TO FIXED DOLLAR AMOUNT. SEE PAGE 10 FOR VARIABLE
PROVISIONS.

We issue this contract in consideration of your application and the
payment of the purchase payments for allocation to Participant
certificates as directed.

Signed for an issued by IDS Life Insurance Company of New York in
Albany, New York, as of the date shown under Contract Data.

President

/s/ John C. Boeder

Secretary

/s/ Michael B. Carlin
<PAGE>
PAGE 2
                   GUIDE TO CONTRACT PROVISIONS

Definitions                   Important words and meanings/Page 3

General Provisions            Entire contract; Certificates;
                              Incontestable; Benefits based upon
                              incorrect data; State laws; Periodic
                              reports; Evidence of survival;
                              Protection of proceeds; Payments by
                              us; Voting rights; Changes in
                              plan/Page 5

Ownership and Beneficiary     Owner rights; Trust or custodial
                              ownership; Change of ownership;
                              Beneficiary; Change of 
                              Beneficiary/Page 6

Payments to Beneficiary       Describes options and amounts payable
                              upon death/Page 7

Purchase Payments             Purchase payments; Amounts and
                              intervals; Payment limits; Allocation
                              of purchase payments; Termination of
                              payments/Page 8

Certificate Value Provisions  Certificate value; Fixed account
                              certificate value; Interest to be
                              credited; Variable accounts
                              certificate value; Administrative
                              charge; Premium tax charges;
                              Transfers of certificate values/
                              Page 9

Fixed and Variable Accounts   Fixed account; Variable accounts;
                              Investments of the variable accounts;
                              Valuation of assets; Accumulation
                              units and values; Net investment
                              factor; Mortality and expense risk
                              charge; Annuity unit value/Page 10

Surrender Provisions          Surrender; Surrender value; Surrender
                              Charge; Rules for surrender/Page 11
                                                                    
                              Suspension or Delay in Payment;
                              Surrenders May Be Taxed; Surrender
                              Restrictions/Page 12

Loan Provisions               Loan amount; Loan interest; Loan
                              period and repayment; Effect of loan
                              on certificate value; Transfers and
                              partial surrenders during loan
                              period; Tax status/Page 13

Annuity Provisions            When annuity payments begin;
                              Different ways to receive annuity
                              payments; Determination of payment
                              amounts/Page 14
<PAGE>
PAGE 3
                   GUIDE TO CONTRACT PROVISIONS
                            (Continued)

Table of Settlement Rates     Tables showing the amount of the
                              first variable annuity payment and
                              fixed annuity payments for the
                              various payment plans/Page 16
<PAGE>
PAGE 4
                           CONTRACT DATA

Contract Date:      February 1, 1993

Contract Number:    Sample

Contract Owner:     ABC School


Group Deferred Annuity Contract for 403(b) Employer-Sponsored Plans


Accounts Available for Allocation of Purchase Payments:

         Variable
         Accounts                      Mutual Fund

             4                  IDS Life Capital Resource Fund
             5                  IDS Life Special Income Fund
             6                  IDS Life Moneyshare Fund
             9                  IDS Life Managed Fund
            10                  IDS Life International Equity Fund
            11                  IDS Life Aggressive Growth Fund

         Fixed Account


Surrender Charge:  Applies to each certificate. See page 11.

                                  Surrender Charge
                                   as % of Amount
           Certificate Year         Surrendered

                1                        8%
                2                        8
                3                        8
                4                        8
                5                        7
                6                        6
                7                        5
                8                        4
                9                        3
               10                        2
               11                        1
          12 and later                   0
 
Surrender charges will not exceed 8 1/2% of purchase payments with
respect to each certificate.

Administrative Charge:   $30 deducted from each certificate's value
                         at the end of each certificate year. See
                         page 9.
                                         
Fixed Account Guaranteed Interest Rate:   3% Annual Effective Rate.
                                         
Loan Interest Rate Charged:               5.7% annually in advance.
                                          See page 13.
<PAGE>
PAGE 5
                          CONTRACT DATA 
                            (Continued)

In order for the dollar amount of variable annuity payments not to
decrease, the assets of the variable accounts must have an annual
net rate of investment return of 3 1/2%. This is equal to a 4 1/2%
gross investment return minus the 1% risk charge.
<PAGE>
PAGE 6
                            DEFINITIONS

The following words are used often in this contract. When we use
these words, this is what we mean:

Annuitant

The Participant named in each certificate on whose life annuity
payments will be based.

Participant

An eligible employee or other person named in the certificate who
is entitled to benefits under the Plan as determined and reported
to us by the Owner.

You, Your

The owner of this contract.

We, Our, Us

IDS Life Insurance Company of New York (IDS Life of New York).

Contract Owner

The employer or other organization which makes application for this
contract.

Participant Enrollment Form

The document or application signed by each Participant that serves
as his or her application for enrollment under the contract.

Plan

The retirement plan under which the contract is issued and which
meets the particular requirements of Section 403(b) of the Internal
Revenue Code of 1986, as amended ("Code").

Purchase Payment (Payment)

An amount paid to Us by or on behalf of a participant as
consideration for the benefits provided by the contract and related
certificates.

Certificate

The document for each Participant which evidences the coverage of
the Participant under the contract.

Certificate Year

Any period of one year commencing with the issue date of a
Participant's certificate and each anniversary thereafter.
<PAGE>
PAGE 7
                            DEFINITIONS
                            (Continued)

Certificate Anniversary

The first day of any certificate year.

Accumulation Unit

An accumulation unit is an accounting unit of measure.  It is used
to calculate a Participant's certificate value prior to settlement.

Annuity Unit

An annuity unit is an accounting unit of measure. It is used to
calculate the value of annuity payments from the variable accounts
on and after the retirement date.

Contract Date

The date from which contract anniversaries, contract years, and
contract months are determined. Your contract date is shown under
Contract Data.

Contract Anniversary
 
The same day and month as the contract date each year that the
contract remains in force.

Certificate Value

The sum of the: (1) Fixed Account certificate value; and (2)
Variable Account certificate value .

Retirement Date

The date elected by the Participant on which annuity payments are
to begin. This date may be changed as provided in this contract.
The participant will be notified prior to the retirement date in
order to select an appropriate annuity payment plan.

Settlement

The application of a Participant's certificate value to provide
annuity payments.

Valuation Date

A valuation date is each day the New York Stock Exchange is open
for trading.

Valuation Period

A valuation period is the interval of time commencing at the close
of business on each valuation date and ending at the close of
business on the next valuation date.

<PAGE>
PAGE 8
                            DEFINITIONS
                            (Continued)

Fixed Account

The fixed account is made up of all our assets other than those in
any separate account.

Variable Accounts

The variable accounts are named under Contract Data. Each is a
separate investment account of ours.

Fixed Annuity

A fixed annuity is an annuity with payments which are guaranteed by
us as to dollar amount during the annuity payment period.

Variable Annuity

A variable annuity is an annuity with payments which (1) are not
predetermined or guaranteed as to dollar amount; and (2) vary in
amount with the investment experience of one or more of the
variable accounts.

Written Request

A request in writing signed by you or a Participant and delivered
to us.

<PAGE>
PAGE 9
                        GENERAL PROVISIONS

Entire Contract

This contract form is the entire contract between you and us.

No one except one of our corporate officers (President, Vice
President, Secretary or Assistant Secretary) can change or waive
any of our rights or requirements under this contract. That person
must do so in writing. None of our representatives or other persons
has the authority to change or waive any of our rights or
requirements under this contract.

Certificates

We shall issue an individual certificate setting forth in substance
the benefits to which each Participant is entitled under this
contract. Nothing in the group annuity contract invalidates or
impairs any right granted to the certificate holder required by
law. Such certificate is not a part of this contract.

Incontestable

The contract and certificates are incontestable from their date of
issue.

Benefits Based on Incorrect Data

If the amount of benefits is determined by data as to a person's
age that is incorrect, benefits will be recalculated on the basis
of the correct data. Any underpayments made by us will immediately
be paid in a single sum with an interest credit of 6% per annum.
Any overpayments made by us will be subtracted from the future
payments together with an interest charge of 6% per annum.

State Laws

This contract is governed by the law of the state in which it is
delivered. The values and benefits of this contract are at least
equal to those required by such state.

Periodic Reports

Statements will be sent to the Owner and Participant quarterly, or
more frequently as the Code may require, showing the number, type
and value of the fixed amounts and accumulation units credited to
the contract and the Participant's certificate. The statement shall
be accurate as of a date not more than two (2) months prior to the
date of mailing. Statements reflecting transactions in each
Participant's certificate as may be required by applicable laws,
rules and regulations will also be sent.
<PAGE>
PAGE 10
                        GENERAL PROVISIONS
                            (Continued)

Evidence of Survival

Where any payments under this contract depend on the recipient or
annuitant being alive on a given date, proof that such condition
has been met may be required by us. Such proof may be required
prior to making the payments.

Protection of Proceeds

Payments under this contract are not assignable by any beneficiary
prior to the time they are due. To the extent allowed by law,
payments are not subject to the claims of creditors or to legal
process.
       
Payments By Us

All sums payable by us are payable at our home office. Any payment
of a variable annuity or surrender based on the variable contract
value shall be payable only from the variable accounts.
       
Voting Rights

We will vote mutual fund shares held by the variable accounts at
meetings of shareholders of the fund(s), in accordance with
instructions received from the Owner, Participants, or other
authorized party. Notice will be given to each person who may be
entitled to vote on any matter. Such notice will specify the
matters upon which the person may be entitled to vote and the
method of determining the number of votes which may be cast at any
such meeting. Fund shares held in each variable account for which
no timely voting instructions are received and fund shares that are
not otherwise attributable to Owners, Participants, or other
authorized party will be voted by the Company in the same
proportion as the shares for which voting instructions are
received.
       
Changes in Plan

Evidence may be requested that the Plan meets the requirements of
qualification under Section 403(b) of the Code. You agree to
provide notification immediately if, at any time, the Plan fails to
meet the requirements of that Section of the Code.
<PAGE>
PAGE 11
                     OWNERSHIP AND BENEFICIARY

Owner's Rights

Unless otherwise provided in this contract, you may exercise all
rights and privileges provided in this contract or allowed by us. 
Participants rights under the contract are subject to the terms of
the Owner's Plan.

Trust or Custodial Ownership

If you are a tax qualified trust or tax qualified custodial
account, then your trustees or custodian (or their successors)
properly named by your trust or custodial agreement may exercise
all rights and privileges provided in this contract or allowed by
us.

Change of Ownership (Restricted)

Your right to change the ownership of this contract is restricted. 
This contract may not be sold, assigned, transferred, discounted or
pledged as collateral for a loan or as security for the performance
of an obligation or for any other purpose to any person other than
to us.  The Participants vested rights under this contract are
nonforfeitable and this contract or the rights under it may not be
transferred to any person other than to us.

Beneficiary

Beneficiaries are those named by the Participant in accordance with
applicable provisions of the Plan and the Code, in a form
satisfactory to us, to receive benefits of the certificate if the
Participant dies while the certificate is in force.

Unless you have provided otherwise, only those beneficiaries who
are living on the date of death may share in the benefits, if any. 
If no beneficiary is then living, we will pay the benefits to the
Participant's estate.

Change of Beneficiary

The Participant may change the beneficiary anytime while the
annuitant is living by satisfactory written request.  Once the
change is received by us, it will take effect as of the date of
your request, subject to any action taken or payment made before
the recording.
<PAGE>
PAGE 12
                      PAYMENTS TO BENEFICIARY

Death Benefit Before the Retirement Date

If the Participant dies before the retirement date and age 75 while
the certificate is in force we will pay to the beneficiary the
greater of:

1.   the certificate value; or

2.   the purchase payments paid less any amounts surrendered.
       
If the Participant dies before the retirement date and on or after
the Participant's 75th birthday, while the certificate is in force,
we will pay to the beneficiary the certificate value.

The above amount will be payable in a lump sum upon the receipt of
due proof of death of the Participant. The beneficiary may elect to
receive payment anytime within 5 years after the date of death of
the Participant.

In lieu of a lump sum, payment may be made under an Annuity Payment
Plan, provided:

1.   the beneficiary elects the plan within 60 days after we
     receive due proof of death; and

2.   payments begin no later than one year after the date of death;
     and

3.   the plan provides payments over a period which does not exceed
     the life of the beneficiary, or the life expectancy of the
     beneficiary.
       
In this event, the reference to "annuitant" in the Annuity
Provisions shall apply to the beneficiary.

Any amounts payable or applied by us as described in this section
will be based on the certificate value as of the valuation date on
or next following the date on which due proof of death is received
at our home office.

Spouse Option to Continue Certificate Upon Annuitant's Death

If the Participant dies prior to the retirement date, a spouse who
is designated as sole beneficiary may elect in writing to forego
receipt of the death benefit and instead continue the certificate
in force. The election by the spouse must be made within 60 days
after we receive due proof of death. The spouse may not make
additional purchase payments to the certificate.

In this event, the retirement date may not be later than the
April 1 following the calendar year in which the Participant would
have attained age 70 1/2, or such other date which allows the
spouse to satisfy the minimum distribution requirements under the
Code, its regulations and/or promulgations by the Internal Revenue
Service.
<PAGE>
PAGE 13
                      PAYMENTS TO BENEFICIARY
                            (Continued)

Annuitant's Death After the Retirement Date

If the annuitant dies after the retirement date, the amount
payable, if any, will be as provided in the Annuity Payment Plan
then in effect.

<PAGE>
PAGE 14
                         PURCHASE PAYMENTS

Purchase Payments

Purchase payments are the payments made by, or on behalf of, the
participant under this contract for the benefits it provides. 
Purchase payments must be paid or mailed to us or to an authorized
agent.  If requested, we'll give you a receipt for your purchase
payments.  Upon payment to us, purchase payments become our
property.

Net purchase payments are that part of the purchase payments
applied to the certificate value. A net purchase payment is equal
to the purchase payment less any applicable premium tax charge.

Amount and Intervals

Purchase payments may be paid in a single sum or in installments
until the earlier of: (1) the date a Participant's certificate
terminates by surrender or otherwise; or (2) the date on which
annuity payments begin for the Participant.

Subject to the Payment Limits Provision the Participant may: (1)
stop and/or restart purchase payments; or (2) increase or decrease
the amount of purchase payments; or (3) change the interval of
purchase payments.

Payment Limits Provision

Maximum Purchase Payments - The maximum purchase payments in the
first or later years may not exceed the applicable limits allowed
under the Code and Plan.

Minimum Purchase Payments - The minimum purchase payment is $25 per
month which on an annualized basis equals $300.

We also reserve the right to cancel a certificate if both of the
following conditions exist at the same time: (1) no purchase
payments have been paid for a continuous period of 36 months; and
(2) less than $600 in purchase payments have been paid under the
certificate. In this event we will give the Participant 30 days
written notice of our intent to cancel the certificate.  Upon such
cancellation we will pay the Participant the certificate value in
one sum. The certificate will then terminate.

Allocation of Purchase Payments

Participants shall give instructions on how purchase payments are
to be allocated among the fixed account and variable accounts.
Choices for each account may be made in any whole percent from 0%
to 100% as long as the total adds up to 100%.  A participants'
Allocation instructions as of the certificate date will be shown in
the certificate. By written request, or by another method agreed
upon, participants may change their choice of accounts or
percentages. The first net purchase payment will be allocated as of
the end of the valuation period during which we make an affirmative
<PAGE>
PAGE 15
                         PURCHASE PAYMENTS
                            (Continued)

decision to issue the certificate. Net purchase payments after the
first will be allocated as of the end of the valuation period
during which we receive the payment at our home office.

Termination of Payments

If purchase payments made by or on behalf of a Participant are
terminated for any reason prior to the retirement date, the
Participant may elect to surrender the certificate value in
accordance with any applicable provisions of this contract, the
Plan or the Code or leave the certificate in force under the
contract until the certificate value is surrendered, paid upon the
Participant's death or applied to an annuity payment plan. When the
certificate remains in force under the contract, any monies
allocated to the variable accounts will continue to reflect the net
investment experience of the funds. If the total certificate value
becomes less than $600, we reserve the right to pay the certificate
value to the Participant in a lump sum.

The Participant also may transfer the certificate under a group
deferred annuity contract held by another contract owner that is
issued by us under the same policy form.

<PAGE>
PAGE 16
                   CERTIFICATE VALUE PROVISIONS

Certificate Value

A participant's certificate value at any time is the sum of (1) the
Fixed Account certificate value; and (2) the Variable Account
certificate value.

If: (1) part or all of the certificate value is surrendered; or (2)
charges described herein are made against the certificate value;
then a number of accumulation units from the variable accounts and
an amount from the fixed account will be deducted to equal such
amount. For surrenders, deductions will be made from the fixed or
variable accounts that are specified. Otherwise, the number of
units from the variable accounts and the amount from the fixed
account will be deducted in the same proportion that the
participants' interest in each bears to the total certificate
value.

Fixed Account Certificate Value

The fixed account certificate value at any time will be: (1) the
sum of all amounts credited to the fixed account under the
certificate; less (2) any amounts deducted for charges or
surrenders.

Interest to be Credited

We will credit interest to the fixed account certificate value.
Interest will begin to accrue on the date the purchase payments
which are received in our home office become available to us for
use. Such interest will be credited at rates that we determine from
time to time. However, we guarantee that the rate will not be less
than the Guaranteed Interest Rate shown under Contract Data.

Variable Account Certificate Value

The variable account certificate value at any time will be: (1) the
sum of the value of all variable account accumulation units under
the certificate resulting from purchase payments so allocated, or
transfers among the variable and fixed accounts; less (2) any units
deducted for charges or surrenders.

Administrative Charge

We charge a fee for establishing and maintaining our records for
each certificate under this contract. The charge is shown under
Contract Data and is deducted from the certificate value at the end
of each certificate year or, if earlier, when the certificate is
surrendered. The charge does not apply after annuity payments begin
for each participant. We reserve the right to reduce or eliminate
the administrative charge.
             
Premium Tax Charges

We reserve the right to deduct an amount from a participant's
certificate value for any applicable premium taxes not previously
deducted.
<PAGE>
PAGE 17
                   CERTIFICATE VALUE PROVISIONS
                            (Continued)

Transfers of Certificate Values

While a certificate is in force prior to the settlement date,
transfers of certificate account values may be made as outlined
below:

1.   Subject to provisions of the Plan, Participants may transfer
     all or a part of the values held in one or more of the
     variable accounts to another one or more of the variable
     accounts. Subject to item 2, participants may also transfer
     values held in one or more of the variable accounts to the
     fixed account.

2.   Once per year subject to provisions of the Plan, Participants
     may transfer values from the fixed account to one or more of
     the variable accounts. If such a transfer is made, no
     transfers from a variable account to the fixed account may be
     made until the next eligible period as defined in the Plan.

Participants may make a transfer by written request.  There is no
fee or charge for these transfers. However, the minimum transfer
amount is $250, or if less, the entire value in the account from
which the transfer is being made.
             
In lieu of the above, participants can set up scheduled transfers
on a monthly or quarterly basis. The minimum transfer amount is
$50. The maximum scheduled transfer from the fixed account, when it
is established, is limited to the current value of the fixed
account divided by 12.
<PAGE>
PAGE 18
                    FIXED AND VARIABLE ACCOUNTS

The Fixed Account

The fixed account is our general account.  It is made up of all of
our assets other than: (1) those in the variable accounts; and (2)
those in any other segregated asset account.

The Variable Accounts

The variable accounts are separate investment accounts of ours.
They are named under Contract Data. We have allocated a part of our
assets for this and certain other contracts to the variable
accounts. Such assets remain our property. However, they may not be
charged with the liabilities from any other business in which we
may take part.

Investments of the Variable Accounts

Purchase payments applied to the variable accounts will be
allocated as specified by the Participant. Each variable account
will buy, at net asset value, shares of the fund shown for that
account under Contract Data or as later added or changed.

Valuation of Assets

Mutual fund shares in the variable accounts will be valued at their
net asset value.

Variable Account Accumulation Units

The number of accumulation units for each of the variable accounts
is found by dividing: (1) the net amount allocated to the account;
by (2) the accumulation unit value for the account for the
valuation period during which we received the purchase payment.

Variable Account Accumulation Unit Value

The value of an accumulation unit for each of the variable accounts
was arbitrarily set at $1 when the first mutual fund shares were
bought. The value for any later valuation period is found as
follows:

     The accumulation unit value for each variable account for the
     last prior valuation period is multiplied by the net
     investment factor for the same account for the next following
     valuation period. The result is the accumulation unit value.
     The value of an accumulation unit may increase or decrease
     from one valuation period to the next.

Net Investment Factor

The net investment factor is an index applied to measure the
investment performance of a variable account from one valuation
period to the next. The net investment factor may be greater or
less than one; therefore, the value of an accumulation unit may
increase or decrease.
<PAGE>
PAGE 19
                    FIXED AND VARIABLE ACCOUNTS
                            (Continued)

The net investment factor for any such account for any valuation
period is determined by: dividing (1) by (2) and subtracting (3)
from the result.  This is done where:

(1) is the sum of:

     a.   the net asset value per share of the mutual fund held in
          the variable account determined at the end of the current
          valuation period; plus

     b.   the per share amount of any dividend or capital gain
          distributions made by the mutual fund held in the
          variable account, if the "ex-dividend" date occurs during
          the current valuation period.

(2)  is the net asset value per share of the mutual fund held in
     the variable account, determined at the end of the last prior
     valuation period.

(3)  is a factor representing the mortality and expense risk
     charge.

Mortality and Expense Risk Charge

In calculating accumulation unit values we will deduct a mortality
and expense risk charge from the variable accounts equal, on an
annual basis, to 1.00% of the daily net asset value. This deduction
is made to compensate us for assuming the mortality and expense
risks under contracts of this type. We estimate that approximately
2/3 of this charge is for assumption of mortality risk and 1/3 is
for assumption of expense risk. The deduction is: (1) made from
each variable account; and (2) computed on a daily basis.

Annuity Unit Value

The value of an annuity unit for each variable account was
arbitrarily set at $1 when the first mutual funds were bought. The
value for any later valuation period is found as follows:

1.   The annuity unit value for each variable account for the last
     prior valuation period is multiplied by the net investment
     factor for the account for the valuation period for which the
     annuity unit value is  being calculated.

2.   The result is multiplied by an interest factor. This is done
     to neutralize the assumed investment rate which is built into
     the annuity tables on page 16.
<PAGE>
PAGE 20
                       SURRENDER PROVISIONS

Surrender

By written request and subject to requirements under the Plan and
the rules below a Participant may:

1.   surrender the certificate for the total surrender value; or
       
2.   partially surrender the certificate for a part of the
     surrender value.
       
Surrender Value
       
The surrender value at any time will be:
       
1.   the certificate value;
       
2.   minus the administrative charge;
       
3.   minus any surrender charge.
       
Surrender Charge
       
The surrender charge shall apply to surrenders by each participant
and is based on:

1.   the amount surrendered; and

2.   the certificate year in which a surrender is made.
       
The schedule of surrender charges is shown under Contract Data. We
reserve the right to reduce or eliminate the surrender charges.

Surrender charges shall not apply if amounts are distributed due to
the following:

1.   a Participant's retirement under the Plan on or after Age 55,
     or
       
2.   death of the Participant, or
       
3.   settlement of the certificate  under an Annuity Payment Plan
     as described herein.

Rules For Surrender

All surrenders will have the following conditions:

1.   The Participant must apply by written request or other method
     agreed to by us: (a) while the certificate is in force; and
     (b) prior to the earlier of the retirement date or the death
     of the Participant.
       
2.   The Participant must surrender an amount equal to at least
     $250. The certificate value after a partial surrender must be
     at least $600.
       <PAGE>
PAGE 21
                       SURRENDER PROVISIONS
                            (Continued)

3.   The amount surrendered, less any charges, will normally be
     paid to the Participant within seven days of the receipt of
     written request and the certificate, if required. For
     surrenders from the fixed account, we have the right to defer
     payment for up to 6 months from the date we receive the
     request.
       
4.   For partial surrenders, if the Participant does not specify
     from which accounts the surrender is to be made, the surrender
     will be made from the variable accounts and fixed account in
     the same proportion as the Participant's interest in each
     bears to the certificate value.
       
Upon surrender for the full surrender value the certificate will
terminate. We may require return of the certificate to us before we
pay the full surrender value.

Suspension or Delay in Payment of Surrender

We have the right to suspend or delay the date of any surrender
payment from the variable accounts for any period:

1.   When the New York Stock Exchange is closed; or
       
2.   When trading on the New York Stock Exchange is restricted; or
       
3.   When an emergency exists as a result of which: (a) disposal of
     securities held in the variable accounts is not reasonably
     practicable; or (b) it is not reasonably practicable to fairly
     determine the value of the net assets of the variable account;
     or
       
4.   During any other period when the Securities and Exchange
     Commission, by order, so permits for the protection of
     security holders.
       
Rules and regulations of the Securities and Exchange Commission
will govern as to whether the conditions set forth in 2 and 3
exist.

Surrenders May Be Taxed

The earnings portion of any surrender is subject to tax as income,
possible penalty charges and 20% withholding according to the
Internal Revenue Code.

Surrender Restrictions Before Age 59 1/2

Section 403(b) of the Code prohibits any distributions from the
contract or certificate unless the Participant has:
       
1.   attained age 59 1/2; or

2.   separated from service of the employer; or
<PAGE>
PAGE 22
                       SURRENDER PROVISIONS
                            (Continued)

3.   died; or

4.   become disabled (as defined in Section 72(m)(7) of the Code;
     or
       
5.   encountered hardship (within the meaning of Section 403(b) of
     the Code;
       
and then only such amounts that the Code may provide.
       
We shall require satisfactory written proof of the event(s) in
items 1 through 5 above prior to any distribution.

<PAGE>
PAGE 23
                          LOAN PROVISIONS

Loan Amount

We may make loans from the Fixed Account Certificate Value to the
Participant at any time before retirement payments begin. The
security for the loan will be the Fixed Account Certificate Value.
A loan cannot exceed $50,000 or one-half of the Certificate Value,
whichever is less. In no event will such amount exceed 93 % of the
Fixed Account Certificate Value. If the Participant has taken a
plan loan in the past, the $50,000 limit may be reduced. The
reduction equals $50,000 minus the excess, if any of (a) the
highest loan balances owed during the prior one-year period, over
(b) the balances currently owed.  If one-half of the Certificate
Value is less than $10,000, we may make a loan in such other amount
provided in the loan agreement and permitted under applicable law.
Loans of less than $600 will not be permitted.

Loan Interest

During the loan term, the fixed account certificate value equal to
the value of the loan will continue to earn interest at a rate of
4% per year compounded annually in lieu of the current interest
rate. Loan interest will be charged on the outstanding loan balance
at a rate of 5.7% per year payable annually in advance, unless a
different rate is required by applicable federal law. In no event
will the rate exceed the maximum rate prescribed for
contracts/certificates of this type in the state where the
certificate is issued.
 
Loan Period and Repayment

Loans plus interest must be repaid within 5 years unless the loan
request and supplemental loan agreement specify that the loan
period will be 10 years and is agreed to by us.

Loan repayments will be due at the times set forth in the loan
agreement. If the loan balance outstanding, plus interest, is not
repaid by the end of the loan period or prior to surrender or
settlement of the certificate, the loan balance, plus interest and
any surrender charge, will be deducted from the Fixed Account
Certificate Value and paid to us. The loan balance plus interest
will be treated as a surrender. (Caution: such a surrender before
age 59 1/2 may result in a tax penalty.)

The loan may be repaid in full or in part as provided in the loan
agreement before the certificate is surrendered or retirement
payments begin.

Effect of Loan on Certificate Value

If the Certificate is surrendered while there is an outstanding
loan, the surrender value will be reduced by the amount of the loan
outstanding plus pro rata loan interest and the surrender charge.
Upon death  of the Participant, the beneficiary will receive the
death benefit reduced by the amount of the loan outstanding plus
pro rata loan interest. If retirement payments start while there is
<PAGE>
PAGE 24
                          LOAN PROVISIONS
                            (Continued)

an outstanding loan, the fixed account certificate value will be
reduced by the amount of the loan outstanding plus pro rata loan
interest.
       
Transfers and Partial Surrenders During Loan Period
       
While there is an existing loan, transfers or partial surrenders
from the fixed account may be made (if otherwise permitted under
the certificate) but only with fixed account values that exceed an
amount determined by dividing the debt by 93 %. In addition, the
certificate value, less any debt, after a partial surrender must be
at least $600.
       
Tax Status

Loans taken under the terms above together with the Loan Request
and Supplemental Loan Agreement are intended to meet the
requirements under Section 72(p) of the Internal Revenue Code (the
Code) as it now exists or may later be amended. With respect to
remaining so qualified, we reserve the right to modify this
contract to comply with: future changes in the Code; any
regulations or rulings issued under the Code; and any other
requirements imposed by the Internal Revenue Service. We will 
provide you notice and copy of any such modifications.

<PAGE>
PAGE 25
                        ANNUITY PROVISIONS

Settlement

When settlement occurs with respect to a Participant, the
certificate value will be applied to make annuity payments under
one of the Annuity Plans described below. The first payment will be
made as of the retirement date. This date is specified in each
Certificate. Before payments begin we will require satisfactory
proof that the annuitant is alive. We may also require the
Participant to exchange the Certificate for a supplemental contract
which provides the annuity payments.

Change of Retirement Date

A Participant may change the retirement date by written request.
The maximum Retirement Date is the later of:

1.   April 1 following the calendar year in which the annuitant
     attains age 70 1/2; or
       
2.   such other date which satisfies the minimum distribution
     requirements under the Code, its regulations and/or
     promulgations by the Internal Revenue Service; or
       
Notwithstanding the above, the maximum Retirement Date is the later
of:

1.   The certificate anniversary on or preceding the Participant's
     85th birthday; or
       
2.   the 10th certificate anniversary.
       
Also, if the Participant selects a new retirement date, it must be
at least 30 days after written request is received.
 
Annuity Payment Plans

Subject to the terms of the Plan and the Code, annuity payments may
be made on a fixed-dollar basis, a variable basis or a combination
of both. The Participant can schedule receipt of annuity payments
according to one of the Plans A through E below or another plan
agreed to by us provided:

1.   the Plan selected provides for payments over the life of the
     annuitant or over the life of the annuitant and a designated
     beneficiary; or
       
2.   the Plan selected provides for payments over a period which
     does not exceed the life expectancy of the annuitant, or the
     life expectancy of the annuitant and a designated beneficiary;
     and

3.   the Plan selected meets the minimum death incidental benefit
     requirements under the Code.

<PAGE>
PAGE 26
                        ANNUITY PROVISIONS
                            (Continued)

     Plan A - This provides monthly annuity payments during the
     lifetime of the annuitant. No payments will be made after the
     annuitant dies.
          
     Plan B - This provides monthly annuity payments during the
     lifetime of the annuitant with a guarantee by us that payments
     will be made for a period of at least five, ten or fifteen
     years.  You must select the guaranteed period.
          
     Plan C - This provides monthly annuity payments during the
     lifetime of the annuitant with  a guarantee by us that
     payments will be made for a certain number of months. We
     determine the number of months by dividing the amount applied
     under this Plan by the amount of the first monthly annuity
     payment.
          
     Plan D - Monthly payments will be paid during the lifetime of
     the annuitant and a joint annuitant. When either the annuitant
     or the joint annuitant dies we will continue to make monthly
     payments during the lifetime of the survivor. No payments will
     be paid after the death of both the annuitant and joint
     annuitant.
          
     Plan E - (Installment for a specified period) This provides
     monthly fixed dollar annuity payments for a period of years.
     The period of years may be no less than 10 nor more than 30.
          
By written request at least 30 days before the Retirement Date, the
Participant may select the Plan. If at least 30 days before the
Retirement Date the Participant has not selected a Plan, we will
make fixed-dollar payments according to Plan B with payments
guaranteed for ten years unless this option is contrary to
applicable provisions of the Plan or the Code.
    
If you select a Plan that has a payment amount that is the same as
another Plan having a longer guarantee period, then the Plan with
the longer guarantee period will be deemed to have been chosen.
    
If the amount to be applied to a Plan would not provide an initial
monthly payment of at least $20, we have the right to make a lump
sum payment of the certificate value.

Fixed Annuity

A fixed annuity is an annuity with payments that are guaranteed by
us as to dollar amount. Fixed annuity payments after the first
payment will never be less than the amount of the first payment. At
settlement, the fixed account certificate value will be applied to
the applicable Annuity Table. This will be done in accordance with
the Payment Plan chosen. The amount payable for each $1,000 so
applied is shown in Table B on page 17.

<PAGE>
PAGE 27
                        ANNUITY PROVISIONS
                            (Continued)

Variable Annuity

A variable annuity is an annuity with payments which: (1) are not
predetermined or guaranteed as to dollar amount; and (2) vary in
amount with the investment experience of the variable accounts.

Determination of First Variable Annuity Payment

At settlement, the variable account certificate value will be
applied to the applicable Annuity Table. This will be done: (1) on
the valuation date on or next preceding the seventh calendar day
before the retirement date; and (2) in accordance with the Payment
Plan chosen.  The amount payable for the first payment for each
$1,000 so applied is shown in Table A on page 16.

Variable Annuity Payments After the First Payment

Variable annuity payments after the first payment vary in amount.
The amount changes with the investment performance of the variable
accounts. The dollar amount of variable annuity payments after the
first is not fixed. It may change from month to month. The dollar
amount of such payments is determined as follows:

1.   The dollar amount of the first annuity payment is divided by
     the value of an annuity unit as of the valuation date on or
     next preceding the seventh calendar day before the retirement
     date. This result establishes the fixed number of annuity
     units for each monthly annuity payment after the first
     payment. This number of annuity units remains fixed during the
     annuity payment period.
       
2.   The fixed number of annuity units is multiplied by the annuity
     unit value as of the valuation date on or next preceding the
     seventh calendar day before the date the payment is due. This
     result establishes the dollar amount of the payment.
       
We guarantee that the dollar amount of each payment after the first
will not be affected by variations in expenses or mortality
experience.

Exchange of Annuity Units

Annuity units of any variable account may be exchanged for units of
any of the other variable accounts. This may be done no more than
once a year. Once annuity payments start no exchanges may be made
to or from any fixed annuity.
<PAGE>
PAGE 28
                     TABLE OF SETTLEMENT RATES

Annuity payments for each $1,000 of value applied under a Payment
Plan will be based on our table of settlement rates in effect on
the date of settlement. The amount of the first monthly variable
annuity payment, based on a 3 1/2% assumed investment return, is
guaranteed to be not less than the amount shown in Table A for the
adjusted age of the annuitant(s). The amount of the first and all
subsequent fixed dollar annuity payments is guaranteed to be not
less than the amount shown in Table B for the adjusted age of the
annuitant(s).  Adjusted Age shall be equal to the age nearest
birthday minus an "adjustment" depending on the calendar year of
birth of the annuitant as follows:

Calendar                    Calendar
Year of                     Year of
Annuitant's        Adjust-  Annuitant's         Adjust-
Birth               ment    Birth                ment
Prior to 1920         0     1945 through 1949      6
1920 through 1924     1     1950 through 1959      7
1925 through 1929     2     1960 through 1969      8
1930 through 1934     3     1970 through 1979      9
1935 through 1939     4     1980 through 1989     10
1940 through 1944     5     After 1989            11

<PAGE>
PAGE 29
                     TABLE OF SETTLEMENT RATES
                            (Continued)
<TABLE>
<CAPTION>
_____________________________________________________________________________________________________________________________
TABLE A Dollar Amount of First Monthly Variable Annuity Payment Per $1,000 Applied
_____________________________________________________________________________________________________________________________
        PLAN A               PLAN B                   PLAN C                     PLAN D-Joint and Survivor
                                                                                 Adjusted age of Joint Annuitant
_____________________________________________________________________________________________________________________________
Adj.    Life     5 Years     10 Years    15 Years     With     Adj.    10 Years     5 Years     Same     5 Years   10 Years
Age*    Income   Certain     Certain     Certain      Refund   Age*    Younger      Younger     Age      Older     Older
_____________________________________________________________________________________________________________________________
<C>     <C>      <C>         <C>         <C>          <C>      <C>     <C>          <C>         <C>      <C>       <C>
40      3.73     3.73        3.72        3.71         3.69     40      3.34         3.41        3.48     3.54      3.59
41      3.76     3.76        3.76        3.75         3.72     41      3.36         3.44        3.51     3.57      3.62
42      3.80     3.80        3.80        3.78         3.76     42      3.39         3.46        3.53     3.60      3.65
43      3.84     3.84        3.84        3.82         3.80     43      3.41         3.48        3.56     3.63      3.69
44      3.89     3.88        3.88        3.86         3.83     44      3.43         3.51        3.59     3.66      3.73
45      3.93     3.93        3.92        3.91         3.87     45      3.45         3.54        3.62     3.70      3.76
46      3.98     3.98        3.97        3.95         3.92     46      3.48         3.57        3.66     3.74      3.80
47      4.03     4.03        4.02        4.00         3.96     47      3.50         3.60        3.69     3.78      3.85
48      4.08     4.08        4.07        4.05         4.01     48      3.53         3.63        3.73     3.82      3.89
49      4.14     4.13        4.12        4.10         4.06     49      3.56         3.66        3.77     3.86      3.94
50      4.20     4.19        4.18        4.15         4.11     50      3.59         3.70        3.81     3.91      3.99
51      4.26     4.25        4.24        4.21         4.16     51      3.62         3.74        3.85     3.96      4.04
52      4.32     4.32        4.30        4.26         4.22     52      3.65         3.78        3.90     4.01      4.10
53      4.39     4.38        4.36        4.33         4.27     53      3.69         3.82        3.95     4.06      4.16
54      4.46     4.46        4.43        4.39         4.34     54      3.73         3.86        4.00     4.12      4.22
55      4.54     4.53        4.51        4.46         4.40     55      3.76         3.91        4.05     4.18      4.29
56      4.62     4.61        4.58        4.53         4.47     56      3.80         3.96        4.11     4.25      4.36
57      4.71     4.70        4.66        4.60         4.54     57      3.85         4.01        4.17     4.31      4.44
58      4.80     4.79        4.75        4.68         4.62     58      3.89         4.06        4.23     4.39      4.52
59      4.90     4.88        4.84        4.76         4.70     59      3.94         4.12        4.30     4.47      4.60
60      5.00     4.99        4.93        4.84         4.78     60      3.99         4.18        4.37     4.55      4.70
61      5.11     5.09        5.03        4.93         4.87     61      4.04         4.25        4.45     4.64      4.79
62      5.23     5.21        5.14        5.02         4.96     62      4.10         4.31        4.53     4.73      4.90
63      5.36     5.33        5.25        5.12         5.06     63      4.16         4.39        4.62     4.83      5.01
64      5.49     5.46        5.37        5.21         5.17     64      4.22         4.47        4.71     4.94      5.13
65      5.64     5.60        5.50        5.31         5.28     65      4.29         4.55        4.81     5.05      5.26
66      5.79     5.75        5.63        5.42         5.39     66      4.36         4.64        4.92     5.18      5.40
67      5.95     5.91        5.77        5.53         5.52     67      4.44         4.73        5.03     5.31      5.54
68      6.13     6.08        5.91        5.63         5.65     68      4.52         4.83        5.15     5.45      5.70
69      6.32     6.26        6.07        5.74         5.79     69      4.60         4.94        5.28     5.61      5.87
70      6.53     6.46        6.23        5.86         5.94     70      4.70         5.05        5.43     5.77      6.06
71      6.75     6.67        6.40        5.97         6.09     71      4.79         5.18        5.58     5.95      6.25
72      6.99     6.89        6.58        6.08         6.26     72      4.90         5.31        5.74     6.14      6.47
73      7.26     7.13        6.76        6.18         6.44     73      5.01         5.45        5.92     6.35      6.70
74      7.54     7.39        6.95        6.29         6.29     74      5.13         5.61        6.11     6.58      6.96
75      7.85     6.67        7.14        6.39         6.83     75      5.26         5.77        6.32     6.82      7.22
_____________________________________________________________________________________________________________________________
* Adjusted age of annuitant.
_____________________________________________________________________________________________________________________________
Table A above is based on the "1983 Individual Female Annuitant Mortality Table A."  Settlement rates for any age not shown above,
will be calculated on the same basis as those rates shown in the table above.  Such rates will be furnished by us upon request.

Fixed dollar annuity payments will not be less than those shown in Table B.  In addition, the amount of such payments will not be
less than that which would be provided if a single premium immediate annuity contract then offered by us to annuitant's in the same
class was to be purchased with the greater of: (1) the surrender value of this contract; or (2) 95% of the contract value of this
contract.
</TABLE>
<PAGE>
PAGE 30
<TABLE>
<CAPTION>
                                    TABLE OF SETTLEMENT RATES
                                           (Continued)

_________________________________________________________________________________________________________
TABLE B Dollar Amount of Each Monthly Fixed Dollar Annuity Payment Per $1,000 Applied
_________________________________________________________________________________________________________
       PLAN A             PLAN B              PLAN C                 PLAN D-Joint and Survivor
                                                                     Adjusted Age of Joint Annuitant
_________________________________________________________________________________________________________
Adj.   Life     5 Years   10 Years  15 Years  With     Adj.   10 Years  5 Years  Same   5 Years  10 Years
Age*   Income   Certain   Certain   Certain   Refund   Age*   Younger   Younger  Age    Older    Older
_________________________________________________________________________________________________________
<C>    <C>      <C>       <C>        <C>       <C>      <C>    <C>       <C>     <C>    <C>      <C>
40     3.42     3.42      3.42       3.41      3.38     40     3.03      3.10    3.17   3.24     3.29
41     3.46     3.46      3.46       3.45      3.42     41     3.05      3.13    3.20   3.27     3.32
42     3.50     3.50      3.50       3.49      3.45     42     3.07      3.15    3.23   3.30     3.36
43     3.54     3.54      3.54       3.53      3.49     43     3.10      3.18    3.26   3.33     3.39
44     3.59     3.59      3.58       3.57      3.53     44     3.12      3.21    3.29   3.37     3.43 
45     3.63     3.63      3.63       3.61      3.57     45     3.15      3.24    3.33   3.41     3.47 
46     3.68     3.68      3.67       3.66      3.61     46     3.17      3.27    3.36   3.44     3.51 
47     3.73     3.73      3.72       3.71      3.66     47     3.20      3.30    3.40   3.48     3.56 
48     3.79     3.79      3.77       3.76      3.70     48     3.23      3.33    3.44   3.53     3.60 
49     3.84     3.84      3.83       3.81      3.75     49     3.26      3.37    3.48   3.57     3.65 
50     3.90     3.90      3.89       3.86      3.80     50     3.29      3.41    3.52   3.62     3.71 
51     3.97     3.96      3.95       3.92      3.86     51     3.32      3.44    3.56   3.67     3.76 
52     4.03     4.03      4.01       3.98      3.91     52     3.36      3.48    3.61   3.72     3.82 
53     4.10     4.10      4.08       4.04      3.97     53     3.39      3.53    3.66   3.78     3.88 
54     4.18     4.17      4.15       4.11      4.03     54     3.43      3.57    3.71   3.84     3.94 
55     4.25     4.25      4.22       4.18      4.10     55     3.47      3.62    3.77   3.90     4.01 
56     4.34     4.33      4.30       4.25      4.17     56     3.51      3.67    3.83   3.97     4.08 
57     4.42     4.41      4.38       4.32      4.24     57     3.56      3.72    3.89   4.04     4.16 
58     4.52     4.50      4.47       4.40      4.31     58     3.60      3.78    3.95   4.11     4.24 
59     4.61     4.60      4.56       4.48      4.39     59     3.65      3.84    4.02   4.19     4.33 
60     4.72     4.70      4.66       4.57      4.48     60     3.71      3.90    4.10   4.28     4.42 
61     4.83     4.81      4.76       4.66      4.56     61     3.76      3.97    4.17   4.36     4.52 
62     4.95     4.93      4.86       4.75      4.66     62     3.82      4.04    4.26   4.46     4.63 
63     5.07     5.05      4.98       4.85      4.75     63     3.88      4.11    4.35   4.56     4.74 
64     5.21     5.18      5.10       4.95      4.86     64     3.94      4.19    4.44   4.67     4.86 
65     5.35     5.32      5.22       5.05      4.97     65     4.01      4.28    4.54   4.79     4.99 
66     5.51     5.47      5.36       5.16      5.08     66     4.08      4.36    4.65   4.91     5.13 
67     5.67     5.63      5.50       5.26      5.20     67     4.16      4.46    4.76   5.04     5.28 
68     5.85     5.80      5.65       5.37      5.33     68     4.24      4.56    4.89   5.19     5.43 
69     6.04     5.98      5.80       5.49      5.47     69     4.33      4.67    5.02   5.34     5.61 
70     6.25     6.18      5.96       5.60      5.61     70     4.42      4.79    5.16   5.51     5.79 
71     6.47     6.39      6.14       5.71      5.76     71     4.52      4.91    5.31   5.69     5.99 
72     6.71     6.62      6.31       5.83      5.93     72     4.63      5.04    5.48   5.88     6.20 
73     6.97     6.86      6.50       5.94      6.10     73     4.74      5.19    5.66   6.09     6.43 
74     7.26     7.12      6.69       6.04      6.28     74     4.86      5.34    5.85   6.32     6.68 
75     7.56     7.39      6.89       6.14      6.48     75     4.99      5.51    6.06   6.56     6.96
_________________________________________________________________________________________________________
*Adjusted age of annuitant.
_________________________________________________________________________________________________________
Table B above is based on the "1983 Individual Annuitant Mortality Table A" assuming a 3% annual effective
interest rate.  Settlement rates for any age not shown above, or any combination of ages not shown above,
will be calculated on the same basis as those rates shown in the table above.  Such rates will be furnished
by us upon request.  Amounts shown in the Table below are based on assuming a 3% annual effective interest
rate.
_________________________________________________________________________________________________________
PLAN E Dollar Amount of Each Monthly Fixed Dollar Annuity Payment Per $1,000 Applied
_________________________________________________________________________________________________________
Years           Monthly              Years              Monthly          Years          Monthly
Payable         Payment              Payable            Payment          Payable        Payment
  10            $ 9.61                 17               $ 6.23             24           $ 4.84
  11              8.86                 18                 5.96             25             4.71
  12              8.24                 19                 5.73             26             4.59
  13              7.71                 20                 5.51             27             4.47
  14              7.26                 21                 5.32             28             4.37
  15              6.87                 22                 5.15             29             4.27
  16              6.53                 23                 4.99             30             4.18
_________________________________________________________________________________________________________
</TABLE>
<PAGE>
PAGE 31
GROUP DEFERRED ANNUITY CONTRACT


- - Employer Plan
- - Group Deferred Annuity
- - Individual Allocation - Optional fixed dollar or variable
  accumulation values and annuity payments.
- - This contract is nonparticipating. Dividends are not payable.




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


<PAGE>
PAGE 1
Form 38609A (5/94)

Participant Enrollment Form (for Employee Benefit Annuity)

Group Billing Number _____________

IDS Home Office Use Only
Certificate Number ___-___-___-___

Participant Information

Name ______________________________ 
     Last    First     M.I.

Soc. Sec. No. ___________________

Address _________________________________________________________

City ___________________________ State _____ Zip ______ 

Telephone No. _____________

Date of Birth _____ Date of Hire _____ 

Marital Status: __ Married __ Single

Sex: __ M __ F

Purchase Payment Election

1) __     Installment Payments totalling $_____ annually.  (Note:
          Minimum $300/Year)

     (Annual Salary $___________)

2) __     Single Payment $ ______.  (Note: Minimum single payment
          of $1,000)

Investment Election

I elect to invest my account in the group annuity as follows:

Fixed Amount                  ___%
Capital Resource Fund         ___%
International Equity Fund     ___%
Aggressive Growth Fund        ___%
Special Income Fund           ___%
Moneyshare Fund               ___%
Managed Fund                  ___%
TOTAL:                        100%

<PAGE>
PAGE 2
Beneficiary Election

If you are married, your spouse must be your beneficiary unless he
or she consents to your naming another beneficiary as described
below.  Name your beneficiary below (to name more than one person
attach a separate piece of paper with the name, relationship,
address and the percentage each person should receive).

Beneficiary Name ________________ Date of Birth ________ 

Relationship ____________

Address __________________ City ______________ State ___ Zip_______

Employer-Sponsored Plans Only - If you are married and have named
someone other than your spouse to receive benefits, he or she must
agree to your designation of beneficiary by completing, in the
presence of a notary public, a separate form entitled "Consent to
Name Non-Spouse Beneficiary."

Signatures and Statements

Is this annuity intended to replace or change any existing life
insurance or annuities? __ Yes __ No

I acknowledge receipt of Prospectuses for the IDS Life Insurance
Company of New York Group Deferred Fixed/Variable Annuity Contract
and the Retirement Annuity Mutual Funds.  I understand that all
benefits and values provided under the contract, when based on
investment experience of a separate account, are variable and are
not guaranteed as to fixed dollar amount.  I understand that the
Certificate issued from this enrollment form will evidence my
participation under the master group annuity contract issued to my
employer and that such documents together with the 403(b)
Retirement Plan constitute my rights and obligations under the
Plan.

Dated at: City ________________ State _________________ 

Date ______________

___________________________   _____________________________
Participant's Signature       Financial Planner's Signature

Complete for Employer-Sponsored 403(b) Plan

Approved By ___________________________ Date __________________

Employer Name _________________________ Contact _______________

Address _______________________________ Telephone No. _________

City ___________ State __ Zip _________

<PAGE>
PAGE 3
Tax-Sheltered Annuity (TSA) Explanation, Disclosure and
Acknowledgment

Check marks indicate that the item has been explained by the IDS
Life Insurance Company of New York planner and is fully understood
by the participating employee.

__ 1.     Contributions may be allocated to purchase (a) variable
          benefits only, (b) fixed benefits only, or (c) a
          combination of both variable and fixed benefits.

__ 2.     To the extent contributions are used to purchase variable
          benefits, the value of the certificate during the years
          prior to retirement, and also the amount of retirement
          benefits, will vary with the investment performance of
          the assets in the variable accounts and not assurance can
          be made as to how many dollars will be available to the
          participant.

__ 3.     Information about administrative and surrender charges;
          mortality and expense fees; and mutual fund management
          fees have been explained.

__ 4.     The main purpose of an annuity is for long-term
          retirement accumulation and benefits and it should be
          purchased for this purpose.

__ 5.     The investments made in accordance with my elections
          shall be for my exclusive benefit and are neither
          assignable nor transferable.

__ 6.     Under current federal income tax law, as a general rule,
          payments to the annuitant/participant will be taxable
          when received, as ordinary income.  Payments also may be
          subject to a 10% IRS early withdrawal penalty tax and 20%
          federal income tax withholding.  (See the prospectus for
          further discussion of the tax treatment.)

__ 7.     The annuity certificate benefits and provisions also may
          be subject to the Employer's qualified plan rules and
          provisions.

__ 8.     Effective 1-1-89 a distribution from a Tax-Sheltered
          Annuity (TSA) purchased under section 403(b) of the
          Internal Revenue Code may be made only if the
          employee/participant has:

     1.   attained age 59 1/2; or
     2.   separated from the service of the employer that purchased
          the TSA; or
     3.   died; or
     4.   become disabled, as defined in Section 72(m)(7) of the
          Code; or
     5.   encountered financial hardship within the meaning of
          Section 403(b) of the Code and as defined in the
          Employer's qualified plan.

<PAGE>
PAGE 4
     The restriction applies to contributions of deferred salary
     made after December 31, 1988, and all earnings credited to the
     TSA after that date.  The "hardship" exception above is
     limited to the amount of contributions made and does not apply
     to any earnings credited to the TSA.

     The restriction does not apply to any values in the TSA as of
     December 31, 1988, nor to transfers or exchanges of
     certificate values within the annuity or to another registered
     variable annuity contract or investment vehicle available
     through the employer.

Participant's Name _______________________ 
                      (Print)
Date ___________________________


_____________________________      ______________________________
Participant's Signature            Financial Planner's
Signature                          Signature

Financial Planner's Report

Declaration and Signature

You certify that you personally solicited this application and
witnessed its signing.  The application and this report are
complete and accurate to the best of your knowledge and belief.

Are you related to the annuitant/participant?  Please state
relationship.  ______________________ (required)

This application __ does __ does not involve replacement of
existing insurance or annuities.

___________________________   _______________     _______________
Financial Planner's           Planner I.D.        Compensation % 
Signature


____ (___)__________
D.O. Phone




___________________________   _______________     _______________
Joint Financial Planner's     Planner I.D.        Compensation % 
Signature


____ (___)__________
D.O. Phone



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