IDS LIFE INSURANCE CO
POS AM, 2000-03-10
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<PAGE>


                       SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                    FORM S-1
                         POST-EFFECTIVE AMENDMENT NO. 13
                     TO REGISTRATION STATEMENT NO. 33-28976

                                      Under

                           The Securities Act of 1933

                           IDS Life Insurance Company
- --------------------------------------------------------------------------------
               (Exact name of registrant as specified in charter)

                                    Minnesota
- --------------------------------------------------------------------------------
            (State or other jurisdiction of incorporation or organization)


                                       63
- --------------------------------------------------------------------------------
                  (Primary Standard Industrial Classification Code Number)

                                   41-0823832
- --------------------------------------------------------------------------------
                      (I.R.S. Employer Identification No.)

                    IDS Tower 10, Minneapolis, MN 55440-0010
                                 (612) 671-3131
- --------------------------------------------------------------------------------
            (Address,   including  zip  code,  and  telephone  number,
             including   area  code,   of   registrant's   principal
             executive offices)

                               Bruce Kohn, Counsel
                           IDS Life Insurance Company
                 IDS Tower 10, Minneapolis, Minnesota 55440-0010
                                 (612) 671-2221
- --------------------------------------------------------------------------------
                    Name, address, including zip code, and telephone number,
                           including area code, of agent for service)

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

<PAGE>

<TABLE>
<CAPTION>

                         Calculation of Registration Fee

- ----------------------- --------------------- -------------------- --------------------- --------------------
<S>                         <C>               <C>                   <C>                   <C>
 Title of each class        Amount to be       Proposed maximum      Proposed maximum         Amount of
 of securities to be         registered       offering price per    aggregate offering    registration fee
      registered                                     unit                 price
- ----------------------- --------------------- -------------------- --------------------- --------------------

Interests in a group            N/A
market value annuity
contract and
individual market
value annuity
contracts for non-tax
qualified purchases.

</TABLE>

<PAGE>


                                     PART I.

                       INFORMATION REQUIRED IN PROSPECTUS

     Attached   hereto   and  made  a  part   hereof  is  the Prospectus.


<PAGE>


American Express Guaranteed Term Annuity
Prospectus, May 1, 2000

IDS Life  Insurance  Company (IDS Life) issues this annuity and offers it in two
ways:


o        a Group Market Value Annuity Contract, and

o        Individual Market Value Annuity Contracts.

To buy this  annuity,  you must  send IDS Life a  purchase  payment  of at least
$5,000 with an application for a contract.

IDS Life Account MGA
Group and Individual Market
Value Annuity Contracts


Issued and sold by:
IDS Life Insurance Company
200 AXP Financial Center
Minneapolis, MN 55474
Telephone: [800-437-0602/800-862-7199]


If you choose not to hold these securities until the end of a guarantee  period,
they  may  be  subject  to  a  substantial  surrender  charge  or  market  value
adjustment. As a result, you could get less than your purchase payment back.

Interest  rates for  renewal  guarantee  periods may be higher or lower than the
previous  guaranteed interest rate. The minimum guaranteed renewal interest rate
is 3%. IDS Life guarantees this rate.


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


IDS Life is not a bank or financial  institution,  and the  securities it offers
are not deposits or obligations of, backed or guaranteed or endorsed by any bank
or financial  institution nor are they insured by the Federal Deposit  Insurance
Corporation,  the Federal Reserve Board or any other agency. Investments in this
annuity involve investment risk including the possible loss of principal.

<PAGE>

Table of contents                                                         Page

The Guaranteed Term Annuity in brief.........................................

Key terms....................................................................

Description of contracts.....................................................
General......................................................................
Application and purchase payment.............................................
Right to cancel..............................................................
Guarantee periods............................................................
Surrenders...................................................................
Surrender charge.............................................................
Market value adjustment......................................................
Premium taxes................................................................
Death benefit prior to settlement............................................
Statement....................................................................
Electing the settlement date and form of annuity.............................

Amendment, distribution and assignment of contracts .........................
Amendment of contracts.......................................................
Distribution of contracts....................................................
Assignment of contracts......................................................

Federal tax considerations...................................................

The Company..................................................................
Business.....................................................................
Investments by IDS Life......................................................
Selected financial data......................................................
Management's discussion and analysis of consolidated
financial condition and results of operations................................

Directors and executive officers.............................................
Executive compensation.......................................................
Security ownership of management.............................................

Legal proceedings............................................................

Experts......................................................................

Appendix A - Partial surrender illustration..................................

Appendix B - Market value adjustment illustration............................

IDS Life financial information...............................................

<PAGE>

The Guaranteed Term Annuity in brief

In this  prospectus,  "we",  "us" and  "IDS  Life"  refer to IDS Life  Insurance
Company and "you" and "yours" refer to an owner who has been issued a contract.

This summary is incomplete. Do not rely on it as a description of your contract.
For more complete information, you must read the entire prospectus. You can find
more  information  about a topic in the  summary by  turning  to the  discussion
beginning at the page listed after that topic in the summary.


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


These market value  annuity  contracts  have a guaranteed  interest rate that we
credit  to the  purchase  payment  when it is  held to the end of the  guarantee
period (the renewal date).  Surrenders  before the renewal date are subject to a
market value adjustment and, if it applies, a surrender charge.


Guarantee  periods:  When you make a payment under an application,  you select a
guarantee period from among those that we offer when we receive your application
and payment.  During this guarantee period,  the purchase payment earns interest
at the  interest  rate  that we have  guaranteed  for your  contract.  We credit
interest daily.  Credited  interest earns interest at the applicable  guaranteed
interest rate we establish. (p.)

Renewal  guarantee  periods:  At the end of each  guarantee  period,  a  renewal
guarantee period of one year will begin,  unless you choose a different  period.
You must  choose the  length of a renewal  guarantee  period  during the 30 days
before the end of the previous  guarantee period.  Beginning on the first day of
each  renewal  guarantee  period,  the renewal  value will earn  interest at the
renewal interest rate that we have guaranteed for your contract and the interest
credited will earn interest at that interest rate. (p.)


Surrenders:  With some restrictions,  we permit partial or total surrenders.  We
may delay payment of any surrender for up to six months from the date we receive
notice of  surrender  or the period  permitted by state law, if less. A delay of
payment  will  not be for  more  than  seven  days  except  under  extraordinary
circumstances.  If we choose to exercise this right,  then during this delay, we
will pay annual  interest  of at least 3% of any  amounts  delayed for more than
thirty days.


Surrender  charge:  If you surrender before the eighth contract  anniversary,  a
surrender  charge  beginning  at a maximum  of 8% of the market  adjusted  value
surrendered will be subtracted from your account. No surrender charge applies if
you surrender on the last day of a guarantee period. We will waive the surrender
charge in certain instances. (p.)


Market value  adjustment:  A market value adjustment  applies when the surrender
occurs  before the  renewal  date.  No market  value  adjustment  applies to any
surrender at the end of a guarantee  period.  We find the market  adjusted value
using the rate we then are paying on purchase  payments  for new  contracts  for
about the same time as the time remaining in your guarantee  period.  Generally,
the amount of the market  value  adjustment  depends a lot on interest  rates on
investments like those we could make with new contract  purchase payments at the
time  you  surrender  and on your  time  remaining  to the end of the  guarantee
period.  The market value  adjustment may increase or decrease the value of your
investment before the renewal date. The amount you receive on surrender could be
less than your original purchase payment if interest rates increase. If interest
rates  decrease,  the amount  you  receive  on  surrender  may be more than your
original purchase payment and accrued  interest.  The market adjusted value also
affects settlements under an annuity payment plan. (p.)


Premium taxes: We may deduct premium taxes from the  accumulation  value of your
contract.  State  premium  taxes  range  from 0 to 3.5% of your  gross  purchase
payments. (p.)


<PAGE>


Death benefit prior to settlement:  The contract provides for a guaranteed death
benefit.  If the annuitant or owner dies before the settlement date, we will pay
to the owner or  beneficiary  the death  benefit  in place of any other  payment
under the contract.  The amount of the death benefit will equal the accumulation
value. (p.)

Choosing the settlement date and form of annuity:  Beginning at a specified time
in the future  picked by the owner called the  settlement  date, we will pay the
owner a lump sum payment or start to pay a series of payments.  You may choose a
series of payments under some annuity plans. (p.)


<PAGE>

Key terms

In this  prospectus,  "we",  "us" and  "IDS  Life"  refer to IDS Life  Insurance
Company and "you" and "yours" refer to an owner who has been issued a contract.

These terms can help you understand details about your annuity:

Accumulation  value - The value of the purchase payment plus interest  credited,
adjusted for any surrenders.

Annuitant - The person on whose life monthly annuity payments depend.

Annuity  -  A  contract   purchased  from  an  insurance   company  that  offers
tax-deferred growth of the purchase payment until earnings are withdrawn.

Cash surrender value - The market  adjusted value less any applicable  surrender
charge. On the last day of a guarantee  period,  the cash surrender value is the
accumulation value.


Contract - a deferred annuity contract,  or a certificate  showing your interest
under a group  annuity  contract,  that  permits  you to  accumulate  money  for
retirement by making a purchase  payment.  A contract provides for a lifetime or
other forms of payouts beginning at a specified time in the future.


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

Contract  date  - The  effective  date  of the  contract  as  designated  in the
contract.

Current interest rate - The applicable  interest rate contained in a schedule of
rates  established  by us at our  discretion  from  time  to  time  for  various
guarantee periods.

Initial  guarantee  period - The period during which the initial  guarantee rate
will be credited.

Initial  guarantee rate - The rate of interest  credited to the purchase payment
during the initial guarantee period.

Market  adjusted value - The  accumulation  value  increased or decreased by the
market  adjusted  value  formula,  on any date  before the end of the  guarantee
period.

Market  value  adjustment  - The market  adjusted  value minus the  accumulation
value.

Owner - The person or entity to whom the annuity contract is issued.

Purchase payment - Payment made to IDS Life for an annuity.


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

o    Individual  Retirement  Annuities  (IRAs) under  Section  408(b) of the
     Internal Revenue code of 1986, as amended (the Code)
o    Roth IRAs under Section 408A of the Code
o    SIMPLE IRAs under Section 408(p) of the Code
o    Simplified  Employee  Pension (SEP) plans under  Section  408(u) of the
     Code
o    Plans  under  Section  401(k) of the Code o Custodial  and  trusted
     pension and profit sharing plans under Section 401(d) of the Code
o    Tax-Sheltered  Annuities (TSA's) under Section 403(b) of the Code


<PAGE>


o    Qualified  annuity plans under Section 403 (a) of the Code
o    Governmental  plans under Section 414(d) of the Code
o    Plans under Section 457 of the Code

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


All other contracts are considered nonqualified annuities.

Renewal date - The first day of a renewal guarantee period. It will always be on
a contract anniversary.

Renewal  guarantee period - A renewal  guarantee period will begin at the end of
each guarantee period as set at our discretion.

Renewal  guarantee  rate - The rate of interest  credited  to the renewal  value
during the renewal guarantee period as set at discretion.

Renewal  value - The  accumulation  value  at the end of the  current  guarantee
period.

Settlement - The application of contract value to provide annuity  payments.  If
the  settlement  date is not the last day of a  guarantee  period,  we apply the
market adjusted value of the contract. On the last day of a guarantee period, we
apply the accumulation value of the contract.

Settlement date - The date on which annuity payments are to begin.

Written  request - A request in writing signed by you and delivered to us at our
corporate office.

Description of contracts

General


This  prospectus  describes  interests in qualified and  nonqualified  group and
individual  market value  annuity  contracts  offered by IDS Life to the general
public.


As described in this prospectus,  the contracts have an interest rate guaranteed
by IDS Life  that we credit  to a  purchase  payment  in the  contract  when the
purchase  payment stays in the contract to its renewal date. We credit  interest
daily to achieve a stated annual  effective rate, based on a 365 day year. We do
not pay interest on leap days (Feb. 29th).  Surrenders prior to the renewal date
are subject to a market value  adjustment,  a surrender  charge (if applicable),
income taxes, and a 10% IRS tax penalty if withdrawn prior to age 59 1/2.

Application and purchase payment


To apply for a contract,  you must  complete an  application  and make a minimum
purchase  payment of $5,000.  For  individuals  age 90 and younger,  the maximum
purchase  payment is $1,000,000  without prior  approval.  This limit applies in
total to all IDS Life  annuities you own. If you purchase the contract to fund a
tax-deferred  retirement  plan,  that plan's  limit on  contributions  also will
apply.  Once we apply a  purchase  payment to a  contract,  we do not permit any
additional purchase payment under the contract.


We will return an improperly completed application, along with the corresponding
purchase payment, five business days after we receive it.

A payment is credited to a contract on the date we receive a properly  completed
application at our corporate office along with the purchase payment. Interest is
earned the next day.  IDS Life then issues a contract  and confirms the purchase
payment in writing.

<PAGE>

Right to cancel

State or  federal  law may give you the right to cancel  the  contract  within a
specific  period of time after  receipt of the  contract and receive a refund of
the entire purchase payment. For revocation to be effective, mailing or delivery
of notice of cancellation must be made in writing to our corporate office at the
following address: IDS Life Insurance Company, Attn: Transactions, P.O. Box 534,
Minneapolis, MN 55440-0534.

Guarantee periods

You select the duration of the  guarantee  period from among those  durations we
offer when we  receive  your  application  and  payment.  As of the date of this
prospectus,  we are offering guarantee periods with annual durations from one to
10  years;  however,  the  guarantee  periods  we offer in the  future  could be
different. The duration selected will determine the guaranteed interest rate and
the purchase payment (less surrenders made and less applicable premium taxes, if
any) will earn  interest  at this  guaranteed  interest  rate  during the entire
guarantee period. Interest is credited to your annuity daily. All interest rates
we quote are  effective  annual  interest  rates.  This  refers to the rate that
results after interest has compounded daily for a full year.

The example below shows how we will credit interest during the guarantee period.
For the purpose of this example, we have made the assumptions as indicated.

Example of guaranteed rate of accumulation

Beginning account value: $50,000
Guaranteed period: 10 years
Guaranteed rate: 6% annual effective rate

      Interest credited to the     Cumulative interest
Year   account during year         credited to the account   Accumulation value

1             $3,000.00                $3,000.00              $53,000.00
2              3,180.00                 6,180.00               56,180.00
3              3,370.80                 9,550.80               59,550.80
4              3,573.05                13,123.85               63,123.85
5              3,787.43                16,911.28               66,911.28
6              4,014.68                20,925.96               70,925.96
7              4,255.56                25,181.51               75,181.51
8              4,510.89                29,692.40               79,692.40
9              4,781.54                34,473.95               84,473.95
10             5,068.44                39,542.38               89,542.38

Guaranteed accumulation value at the end of 10 years is:
$50,000 + $39,542.38 = $89,542.38

Note:  This  example  assumes  no  surrenders  of any  amount  during the entire
ten-year period.  A market value  adjustment  applies and a surrender charge may
apply to any interim surrender (see Surrenders). The hypothetical interest rates
are only illustrations. They do not predict future interest rates to be declared
under the contract.  Actual  interest  rates  declared for any given time may be
more or less than those shown.

<PAGE>

Renewal  guarantee  periods:  At the  end of any  guarantee  period,  a  renewal
guarantee  period  will begin.  We will notify you in writing  about the renewal
guarantee periods  available before the renewal date. This written  notification
will not  specify the  interest  rate for the  renewal  value.  You may elect in
writing,  during the 30-day  period before the end of the  guarantee  period,  a
renewal  guarantee  period of a different  duration from among those we offer at
that  time.  If you do not make an  election,  we will  automatically  apply the
renewal  value to a  guarantee  period  of one  year.  In no event  may  renewal
guarantee  periods  extend  beyond  the  settlement  date then in effect for the
contract.  For  example,  if the  annuitant  is age 82 at the end of a guarantee
period  and the  settlement  date  for the  annuitant  is age 85,  a  three-year
guarantee  period is the maximum  guarantee period that you may choose under the
contract.  The renewal  value will then earn  interest at a guaranteed  interest
rate that we have  declared for this  duration.  We may declare new schedules of
guaranteed interest rates as often as daily.

At the beginning of any renewal guarantee period,  the renewal value will be the
accumulation  value at the end of the guarantee period just ending. We guarantee
the renewal  value with our general  assets.  This amount will earn interest for
the renewal guarantee period at the then applicable guaranteed interest rate for
the  period  selected.  This  rate  may be  higher  or lower  than the  previous
guaranteed interest rate.

At your written request,  we will notify you of the renewal  guarantee rates for
the periods then available.  You also may call us to ask about renewal guarantee
rates.

Establishment of guaranteed interest rates: We will know the guaranteed interest
rate for a chosen  guarantee period at the time we receive a purchase payment or
you renew an accumulation  value. We will send a confirmation that will show the
amount and the  applicable  guaranteed  interest  rate.  The minimum  guaranteed
interest rate for renewal values is 3% per year. The rate on renewal values will
be  equal  to or  greater  than the rate  credited  on new  comparable  purchase
payments at that time.

IDS Life has no specific  formula for  determining  the rate of interest that it
will declare as  guaranteed  interest  rates in the future.  We will declare the
guaranteed  interest  rates from time to time based on our  analysis  of current
market conditions. (See Investments by IDS Life.) In addition, IDS Life also may
consider  various other factors in determining  guaranteed  interest rates for a
given period,  including  regulatory and tax requirements;  sales commission and
administrative  expenses  we bear;  general  economic  trends;  and  competitive
factors. IDS Life in its sole discretion will make the final determination as to
the  guaranteed  interest  rates to be  declared.  We cannot  predict nor can we
guarantee future guaranteed interest rates above the 3% rate.

Surrenders

General:  Subject to certain  tax law and  retirement  plan  restrictions  noted
below, you may make total and partial surrenders under a contract at any time.

For  all  surrenders,  we will  reduce  the  accumulation  value  by the  amount
surrendered  on the surrender date and that amount will be payable to the owner.
We will also reduce the accumulation  value by any applicable  surrender charge.
We will either  reduce or increase  the  accumulation  value by any market value
adjustment applicable to the surrender. IDS Life will, on request, inform you of
the amount payable in a total or partial surrender.


Any  total  or  partial  surrender  may be  subject  to tax and  tax  penalties.
Surrenders  from  certain  tax  qualified  annuities  also may be subject to 20%
income tax withholding. (See Federal tax considerations.)


Tax-sheltered  annuities:  The Code imposes  certain  restrictions on an owner's
right  to  receive  early   distributions   attributable  to  salary   reduction
contributions  from a contract  purchased for a retirement  plan qualified under
Section 403(b) of the Code as a tax-sheltered annuity (TSA).

<PAGE>

Distributions attributable to salary reduction contributions made after Dec. 31,
1988,  plus all earnings  since Dec.  31, 1988,  or to transfers or rollovers of
such amounts from other  contracts,  may come from the TSA contract  only if you
have  attained  age 59-1/2,  have become  disabled as defined in the Code,  have
separated  from the service of your employer that purchased the contract or have
died.

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

Even though these rules may permit a distribution  (e.g.,  for hardship or after
separation from service), it may nonetheless be subject to a 10% IRS penalty tax
(in  addition to income tax) as a premature  distribution  and to 20% income tax
withholding. (See Federal tax considerations.)

These  restrictions  do not apply to transfers of contract  value to another TSA
investment vehicle available through the employer.

Partial  surrenders:  Unless we agree  otherwise,  the  minimum  amount  you may
surrender  is $250.  You cannot make a partial  surrender if it would reduce the
accumulation value of your annuity to less than $2,000.

You may request the net check amount you wish to receive.  We will determine how
much  accumulation  value needs to be  surrendered to yield the net check amount
after any applicable market value adjustments and surrender charge deductions.

You may make a partial surrender request not exceeding $50,000 by telephone.  We
have the authority to honor any telephone  partial surrender request believed to
be authentic and will use  reasonable  procedures to confirm that they are. This
includes  asking  identifying  questions and tape  recording  calls.  As long as
reasonable procedures are followed,  neither IDS Life nor its affiliates will be
liable for any loss resulting from fraudulent requests. At times when the volume
of telephone requests is unusually high, we will take special measures to ensure
that  your  call is  answered  as  promptly  as  possible.  We will not  allow a
telephone surrender request within 30 days of a phoned-in address change.

Total  surrenders:  We will compute the value of your contract at the next close
of business after we receive your request for a complete  surrender.  We may ask
you to return the contract.

Payment on surrender: We may defer payment of any partial or total surrender for
a period  not  exceeding  6  months  from the date we  receive  your  notice  of
surrender or the period  permitted by state  insurance law, if less.  Only under
extraordinary  circumstances will we defer a surrender payment more than 7 days,
and if we defer payment for more than 30 days, we will pay annual interest of at
least 3% on the amount deferred.  While all  circumstances  under which we could
defer  payment  upon  surrender  may  not be  foreseeable  at  this  time,  such
circumstances could include,  for example, our inability to liquidate assets due
to a general  financial  crisis.  If we intend to withhold  payment more than 30
days, we will notify you in writing.

NOTE:  We will charge you a fee if you  request  express  mail  delivery of your
surrender check.

Surrender charge

We may assess a surrender  charge on any total or partial  surrender taken prior
to the eighth contract  anniversary  unless the surrender occurs on the last day
of a guarantee  period.  We will base the amount of the surrender  charge on the
length of the guarantee period.  The table below shows the maximum amount of the
surrender charge.

<PAGE>

Surrender charge percentage:

<TABLE>
<CAPTION>

Guarantee period     Contract years as measured from the beginning of a guarantee period
- -------------------- ----------------------------------------------------------------------------------------
<S>                  <C>        <C>         <C>        <C>        <C>        <C>        <C>        <C>
                     1          2           3          4          5          6          7          8

1 year               1%
2 years              2          1%
3 years              3          2           1%
4 years              4          3           2          1%
5 years              5          4           3          2          1%
6 years              6          5           4          3          2          1%
7 years              7          6           5          4          3          2          1%
8 years              8          7           6          5          4          3          2          1%
9 years              8          7           6          5          4          3          2          1
10 years             8          7           6          5          4          3          2          1
</TABLE>

For renewal guarantee  periods,  we will base the surrender charge on the lesser
of:

o  the length of the new guarantee period, or
o  the number of years remaining until the eighth contract anniversary.

For example,  if a contract owner chose an initial  guarantee  period of 5 years
and  later  a  renewal  guarantee  period  of  4  years,  the  surrender  charge
percentages would be:

      Contract year             Surrender charge

          1                          5%
          2                          4
          3                          3
          4                          2
          5                          1*
          6                          3
          7                          2
          8                          1
          9+                         0

         *0% on last day of 5th contract year.

There will never be any surrender charges after the eighth contract anniversary.

Also, after the first contract anniversary,  surrender charges will not apply to
surrenders of amounts  totalling up to 10% of the  accumulation  value as of the
last contract anniversary.

Surrender charge  calculation:  If there is a surrender  charge, we calculate it
as:

(A minus B) multiplied by P

where:       A =  market adjusted value surrendered
             B    = the  lesser  of A or  10%  of  accumulation  value  on  last
                  contract  anniversary not already taken as a partial surrender
                  this contract year.
             P =  applicable surrender charge percentage

For an illustration of a partial surrender and applicable surrender charges, see
Appendix A.

<PAGE>

Waiver of surrender charge: We will assess no surrender charge:

o    on the last day of a guarantee period;
o    after the eighth contract anniversary;
o    after the first contract anniversary for surrenders of amounts totalling up
     to  10%  of  the  contract  accumulation  value  as of  the  last  contract
     anniversary;
o    upon the death of the annuitant or owner; or
o    upon the  application  of the  market  adjusted  value to  provide  annuity
     payments  under an annuity  payment plan (if such  application  occurs on a
     renewal date, there will be no surrender charge or market value adjustment,
     and the full  accumulation  value will be applied under an annuity  payment
     plan).

In some  cases,  such as  when an  employer  makes  this  annuity  available  to
employees,  we may expect to incur  lower sales and  administrative  expenses or
perform fewer  services due to the size of the group,  the average  contribution
and the use of group  enrollment  procedures.  Then we may be able to  reduce or
eliminate surrender charges. However, we expect this to occur infrequently.

Market value adjustment

We guarantee the accumulation  value,  including the interest  credited,  if the
contract is held until the end of the guarantee period. However, we will apply a
market value  adjustment if a surrender occurs prior to the end of the guarantee
period.  The market  adjusted  value also affects  settlements  under an annuity
payment  plan  occurring  at any time  other  than  the last day of a  guarantee
period.

The market  adjusted value is your  accumulation  value  (purchase  payment plus
interest credited minus surrenders and surrender charges) adjusted by a formula.
The market  adjusted  value  reflects the  relationship  between the  guaranteed
interest  rate on your  contract and the interest  rate we are  crediting on new
Guaranteed  Term Annuity  contracts with guarantee  periods that are the same as
the time remaining in your guarantee period.

The market adjusted value is sensitive to changes in current interest rates. The
difference  between your accumulation value and market adjusted value on any day
will depend on our current  schedule of guaranteed  interest  rates on that day,
the time remaining in your guarantee period and your guaranteed interest rate.

Upon  surrender your market  adjusted value may be greater than your  contract's
accumulation  value, equal to it or less than it depending on how the guaranteed
interest rate on your contract compares to the interest rate of a new Guaranteed
Term Annuity for the same number of years as the guarantee  period  remaining on
your contract.

Before we look at the market  adjusted value  formula,  it may help to look in a
general way at how comparing your contract's  guaranteed rate and the rate for a
new contract affects your market adjusted value.

Relationship  between your  contract's  guaranteed rate and new contract for the
same number of years as the guaranteed period remaining on your contract:

If your annuity rate is:                    Your market adjusted value will be:

greater than the new annuity rate +.25%     greater than your accumulation value

equal to the new annuity rate +.25%         equal to your accumulation value

less than the new annuity rate +.25%        less than your accumulation value


<PAGE>


Let's look at two examples. In order to do so, let's make these assumptions:

o You bought a contract and chose a guarantee period of 10 years.

o We guarantee an interest rate of 4.5% annually  for your 10-year  guarantee
  period.

o After 3 years you decide to surrender  your contract.  In other words,  you
  decide  to  surrender  your  contract  when you  have 7 years  left in your
  guarantee period.

Remember that your market  adjusted value depends partly on the interest rate of
a new  Guaranteed  Term  Annuity for the same  number of years as the  guarantee
period remaining on your contract. In this case, that is 7 years.

Now let's  look at our  examples.  For our  first  example,  remember  that your
contract is earning 4.5%.  Let's assume that new contracts  that we offer with a
7-year  guarantee  period are earning 5.0%. We add 0.25% to the 5.0% rate to get
5.25%.  Your  contract's 4.5% rate is less than the 5.25% rate and, as reflected
in the  table  above,  your  market  adjusted  value  will  be  less  than  your
accumulation value.

For our second example, remember again that your contract is earning 4.5%. Let's
assume  that new  contracts  that we offer  with a 7-year  guarantee  period are
earning 4.0%. We add 0.25% to the 4.0% rate to get 4.25%.  Your  contract's 4.5%
rate is greater than the 4.25% rate and, as  reflected in the table above,  your
market adjusted value will be greater than your accumulation value.

As shown in the table headed "surrender charge  percentage," when your guarantee
period  is 10 years  and you have  begun  your  fourth  contract  year  from the
beginning of the guarantee  period,  your surrender charge  percentage is 5%. In
either of our two  examples,  a 5% surrender  charge would be deducted  from the
market adjusted value.

Market adjusted value formula:

Market adjusted value =                       (Renewal value)
                                          -----------------------
                                          (1 + ic + .0025)(N + t)

Renewal value       --   The accumulation value at the end of the current
                         guarantee period

ic                  --   The current interest rate offered for new Guaranteed
                         Term Annuity contract sales and renewals for the number
                         of years remaining in the guarantee period

N                   --   The number of complete contract years to the end of the
                         current guarantee period

t                   --   The fraction of the contract  year  remaining to the
                         end of the  contract  year  (for  example,  if 180 days
                         remain in a 365 day contract year, it would be .493)

We periodically  declare at our discretion the current guaranteed  interest rate
(ic).  It is the rate we are then paying on purchase  payments and renewals paid
under this class of  contracts  for  guarantee  period  durations  equaling  the
remaining  guarantee  period  duration  of the  contract to which the formula is
being applied.  If the remaining guarantee period is a number of complete years,
we will  use  the  specific  complete  year  guarantee  rate.  If the  remaining
guarantee  period is less than 1 year, we will use the one year guarantee  rate.
If the remaining  guarantee period is a number of complete years plus fractional
years, we will determine the rate by straight line interpolation between the two
years' rates.  For example,  if the remaining  guarantee  period duration is 8.5
years,  and the  current  guaranteed  interest  rate for 8 years is 4% and for 9
years is 5%, IDS Life will use a guaranteed interest rate of 4.5%.

<PAGE>

Market value adjustment formula:

Market value adjustment = Market adjusted value less accumulation value

For an illustration showing an upward and downward adjustment, see Appendix B.

Premium taxes

We  reserve  the right to deduct an amount  from the  accumulation  value of the
contract at the time that any applicable  premium taxes not previously  deducted
are  payable.  If a tax is payable at the time of the  purchase  payment  and we
choose to not deduct it at that time, we further  reserve the right to deduct it
at a later date.  Current  premium taxes range in an amount up to 3.5% depending
on jurisdiction.

Death benefit prior to settlement

If the  annuitant or owner dies before the  settlement  date,  the death benefit
payable to the beneficiary will equal the accumulation value.

If your  spouse is sole  beneficiary  or joint  owner:  Unless you have given us
other  written  instructions,  if you, as owner or joint  owner,  die before the
settlement  date and your spouse is the only  beneficiary  or joint owner with a
right of  survivorship,  your spouse may keep the annuity as owner.  To do this,
your  spouse  must,  within 60 days  after we  receive  proof of death,  give us
written instructions to keep the contract in force.


Section 401(k) plans, TSAs, Section 457 plans, custodial and trusteed plans, and
IRAs,  SIMPLE IRAs and SEPs: If the contract is purchased under a Section 401(k)
plan, Section 403(b) plan,  Section 457 plan,  custodial or trusteed plan or for
an IRA, SIMPLE IRA or SEP, and we receive proof of the annuitant's  death before
the settlement  date, we will pay the  beneficiary  the death benefit  described
above.  If the annuitant dies before reaching the settlement date and the spouse
is the only  beneficiary,  the spouse may keep the  contract  in force until the
date on which  the  annuitant  would  have  reached  70-1/2  or any  other  date
permitted  by the Code.  To do this,  the spouse  must,  within 60 days after we
receive  proof of death,  give us written  instructions  to keep the contract in
force.

Paying the beneficiary:  Unless you have given us other written instructions, we
will pay the  beneficiary in a single  payment.  The  beneficiary  may choose to
receive this payment at any time within 5 years after the date of death. Payment
from a qualified  annuity  (except an IRA,  SIMPLE IRA, SEP or Section 457 plan)
made to a surviving  spouse instead of being directly  rolled over to an IRA may
be subject to 20% income tax withholding. We may make payments under any payment
plan available under this contract if:


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

o payments begin no later than one year after death or any other date permitted
  by the Code; and

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

We will determine the accumulation value at the next close of business after our
death claim requirements are fulfilled.  We will mail payment to the beneficiary
within seven days after our death claim requirements are fulfilled.

Statement

Prior to the  settlement  date,  at least  annually,  we will  send a  statement
showing a summary of the contract.

<PAGE>

Electing the settlement date and form of annuity

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


For non-qualified  annuity,  the settlement date cannot be later than the latest
of:


o    the contract anniversary nearest the annuitant's 85th birthday; or

o    the 10th contract anniversary.


For qualified annuity, to avoid IRS penalty taxes, the settlement date generally
must be:


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

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


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


If you are taking the minimum IRA or TSA  distributions  as required by the Code
from another tax qualified investment, or in the form of partial surrenders from
this  contract,  annuity  payouts  can  start  as late as the  annuitant's  85th
birthday or the 10th contract anniversary.

Annuity payments: The first payment will be made as of the settlement date. Once
annuity  payments  have  started for an  annuitant,  no surrender of the annuity
benefit can be made for the purpose of receiving a lump sum in lieu of payments.

Death after  settlement  date: If you or the annuitant dies after the settlement
date, the amount payable to the  beneficiary,  if any, will continue as provided
in the annuity payment plan then in effect.

Annuity plans:  There are different ways to receive  annuity  payments.  We call
these plans.  You may select one of these plans, or another payment  arrangement
to which we agree,  by  giving us  written  notice at least 30 days  before  the
settlement date.

You may ask us to apply the  market  adjusted  value  (less  applicable  premium
taxes,  if any) on the settlement  date under any of the annuity plans described
below,  but in the  absence of an  election,  we will apply the market  adjusted
value on the  settlement  date under Plan B to provide a life  annuity  with 120
monthly payments certain.


If the  amount to be applied  to an  annuity  plan is not at least  $2,000 or if
payments  are to be made to other  than a natural  person,  we have the right to
make a lump sum payment of the cash  surrender  value.  If a lump sum payment is
from a qualified  annuity  (except an IRA, SIMPLE IRA, SEP or Section 457 plan),
20% income tax withholding may apply.


o    Plan A - This  provides  monthly  annuity  payments for the lifetime of the
     annuitant. We will not make payments after the annuitant dies.

o    Plan B - This  provides  monthly  annuity  payments for the lifetime of the
     annuitant with a guarantee by us that payments will be made for a period of
     at least 5, 10 or 15 years. You must select the period.


<PAGE>

o    Plan C - This  provides  monthly  annuity  payments for 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 market
     adjusted value applied under this plan by the amount of the monthly annuity
     payment.

o    Plan D - We call this a joint and survivor life annuity.  Monthly  payments
     will be paid while both the  annuitant  and a joint  annuitant  are living.
     When either the annuitant or joint annuitant dies, we will continue to make
     monthly  payments until the death of the surviving  annuitant.  We will not
     make payments after the death of the second annuitant.

o    Plan E - This provides  monthly fixed dollar annuity  payments for a period
     of years  that you  elect.  The  period of years may be no less than 10 nor
     more than 30.


Other income plan options may be available.


The  contract  provides  for annuity  payment  plans on a fixed basis only.  The
amount of each  annuity  payment  will not  change  during the  annuity  payment
period. The amount of the annuity payment will depend on:

- --       the market adjusted value (less any applicable premium tax not
         previously deducted) on the date;

- --       the annuity table we are then using for annuity settlements (never less
         than the table guaranteed in the contract);

- --       the annuitant's age; and

- --       the annuity payment plan selected.


The tables for Plans A, B, C and D are based on the "1983  Individual  Annuitant
Mortality  Table A" and an assumed rate of 4% per year.  The table for Plan E is
based on an interest rate of 4%. IDS Life may, at our  discretion,  if mortality
appears more favorable and interest rates justify,  apply other tables that will
result in higher monthly payments.


Restrictions  for some  tax-deferred  plans:  If you  purchased  a qualified
annuity, you must select a payment plan that provides for payments:


o        during the life of the annuitant;

o        during the joint lives of the annuitant and 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 beneficiary.

You  also  must  refer  to the  terms of the  tax-deferred  retirement  plan and
applicable law for any  limitations or  restrictions  on the settlement  date or
annuity payment plan that you may select.

Amendment, distribution and assignment of contracts

Amendment of contracts

We  reserve  the  right to amend  the  contracts  to meet  the  requirements  of
applicable  federal or state laws or regulations.  We will notify you in writing
of any such amendments.

<PAGE>

Distribution of contracts

IDS Life is the principal underwriter for the contracts.  IDS Life is registered
with the Securities and Exchange Commission under the Securities Exchange Act of
1934 (1934 Act) as a broker-dealer  and is a member of the National  Association
of Securities  Dealers,  Inc. IDS Life may enter into selling  agent  agreements
with certain  broker-dealers  registered under the 1934 Act. IDS Life will pay a
maximum commission of 5% of the purchase payment for the sale of a contract.  In
the future,  we may pay a commission  on an election of a  subsequent  guarantee
period by an owner.

Assignment of contracts


You may  change  ownership  of your  annuity  at any time by  filing a change of
ownership form with us at our corporate  office.  No change of ownership will be
binding  upon us until we  receive  and  record  it. If you have a  tax-deferred
retirement plan, the 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 IDS Life; provided,
however,  that if the owner is a trust or custodian,  or an employer acting in a
similar capacity, ownership of a contract may be transferred to the annuitant.

The value of any part of a  nonqualified  annuity  assigned  or pledged is taxed
like  a cash  withdrawal  to the  extent  allocable  to  investment  in  annuity
contracts after Aug. 13, 1982.

Transfer  of  a  nonqualified   annuity  to  another  person  without   adequate
consideration  is  considered  a gift  and the  transfer  will be  considered  a
surrender  of the contract for federal  income tax  purposes.  The income in the
contract  will be  taxed to the  transferor  who may be  subject  to the 10% IRS
penalty tax for early  withdrawal.  The  transferee's  investment in the annuity
will be the value of the annuity at the time of the transfer.  Consult with your
tax advisor before taking any action.


Federal tax considerations

Under current law,  there is no liability for federal income tax on any increase
in the annuity's  value until  payments are made (except for change of ownership
discussed  above in  "Assignment  of  contracts").  However,  since  federal tax
consequences  cannot always be anticipated,  you should consult a tax advisor if
you have any questions about the taxation of your annuity contract.


You are not taxed on your  purchase  payment.  Your purchase  payment  generally
includes purchase payments made with after-tax dollars.  If the purchase payment
was made by you or on your behalf with pre-tax dollars as part of a tax-deferred
retirement  plan,  such amounts are not considered to be part of your investment
in the  contract  and will be taxed  when  paid to you.  The  contract  will not
provide  any  necessary  or  additional  tax  deferral  if it is  used to fund a
retirement plan that is tax-deferred.


If you surrender part or all of your contract  before the date on which you have
decided to begin to receive annuity payments,  you will be taxed on the payments
which you receive,  to the extent that the value of your  contract  exceeds your
investment in the contract, and you may have to pay an IRS penalty tax for early
withdrawal.


If you begin receiving annuity payments under a nonqualified  annuity, a portion
of each  payment  will be subject to tax and a portion of each  payment  will be
considered to be part of your  investment in the contract and will not be taxed.
All amounts  received after your investment in the contract is recovered will be
subject to tax. If you begin receiving payments from a qualified annuity, all of
the payments generally will be subject to taxation except to the extent that the
contributions were from after-tax dollars.


Unlike life insurance  proceeds,  the death benefit under an annuity contract is
not tax  exempt.  The  gain,  if any,  is  taxable  as  ordinary  income  to the
beneficiary in the year(s) he or she receives the payments.
The gain is subject to income tax, not estate or inheritance tax.

<PAGE>


Tax law requires that all nonqualified  deferred annuity contracts issued by the
same company to the same contract owner during a calendar year are to be treated
as a single,  unified  contract.  The amount of income  included  and taxed in a
distribution (or a transaction  deemed a distribution  under tax law) taken from
any one of such contracts is determined by summing all such contracts.

The  income  earned  on  a  nonqualified   annuity  held  by  such  entities  as
corporations,  partnerships  or trusts  generally  will be treated  as  ordinary
income  received  during  that  year.  However,  if the trust was set up for the
benefit of a natural person only, the income will continue to be tax-deferred.


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

o    after you reach age 59-1/2;

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  over  your  life or  life  expectancy  (or  joint  lives  or life
     expectancies of you and your designated beneficiary); or


o    if it is allocable to a purchase payment before Aug. 14, 1982 (except for
     contracts in tax-deferred retirement plan).

These are the major exceptions to the 10% IRS penalty tax. Additional exceptions
may apply  depending  upon  whether  or not the  annuity is tax  qualified.  For
qualified  annuities,  other  penalties apply if you surrender an annuity bought
under your plan before the plan  specifies  that  payments can be made under the
plan.


In general,  if you receive all or part of the  contract  value from an annuity,
withholding  may be imposed  against the taxable  income portion of the payment.
Any  withholding  that is done  represents a prepayment  of your tax due for the
year. You take credit for such amounts on the annual tax return that you file.

If the payment is part of an annuity  payment  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.  As long as you've
provided  us with a valid  Social  Security  Number or  Taxpayer  Identification
Number, you can elect not to have any withholding occur.

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

If a  distribution  is taken from a contract  offered  under a Section  457 Plan
(deferred  compensation  plan of state  and  local  governments  and  tax-exempt
organizations), withholding is computed using payroll methods depending upon the
type of payment.

Some  states  also  impose  withholding  requirements  similar  to  the  federal
withholding  described above. If this should be the case, any payment from which
federal withholding is deducted may also have state withholding 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.

<PAGE>

If you  receive  all or part of the  contract  value  from a  qualified  annuity
(except an IRA, SIMPLE IRA, SEP or Section 457 plan), a mandatory 20% income tax
withholding  generally  will be  imposed  at the time the  payment  is made.  In
addition,  federal income tax and the 10% IRS penalty tax for early  withdrawals
may apply to amounts  properly  includible in income.  This mandatory 20% income
tax withholding will not be imposed if:

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

o    the payment is one 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 made over a
     period of 10 years or more; or

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

These are the major  exceptions  to the  mandatory  20% income tax  withholding.
Payments made to a surviving  spouse instead of being directly rolled over to an
IRA may be subject to 20% income tax withholding. For taxable distributions that
are not subject to the mandatory  20%  withholding,  federal  income tax will be
withheld from the taxable part of your distribution  unless you elect otherwise.
State withholding also may be imposed on taxable distributions.

You will  receive  a tax  statement  for any year  that you  receive  a  taxable
distribution from your annuity contract according to our records.

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

Our discussion of federal tax laws is based upon our understanding of these laws
as  they  are  currently  interpreted.   Either  federal  tax  laws  or  current
interpretations  of them may change.  You are urged to consult  your tax advisor
concerning your specific circumstances.

The Company

Business


IDS Life is a stock  insurance  company  organized in 1957 under the laws of the
State of Minnesota.  IDS Life is a wholly owned  subsidiary of American  Express
Financial  Corporation  (AEFC),  which is a wholly owned  subsidiary of American
Express  Company.  IDS Life acts as a direct  writer of  insurance  policies and
annuities and as the investment  manager of various  investment  companies.  IDS
Life is licensed to write life insurance and annuity  contracts in 49 states and
the  District of Columbia.  The  headquarters  of IDS Life is 200 AXP  Financial
Center, Minneapolis, MN 55474.


IDS Life files reports on Forms 10-K and 10-Q with the  Securities  and Exchange
Commission (SEC). The public may read and copy materials we file with the SEC at
the SEC's Public  Reference  Room at 450 Fifth Street,  N.W.,  Washington,  D.C.
20549.  The  public  may  obtain  information  on the  operation  of the  public
reference  room by  calling  the SEC at  1-800-SEC-0330.  The SEC  maintains  an
Internet site  (http://www.sec.gov) that contains reports, proxy and information
statements,  and other information  regarding  issuers that file  electronically
with the SEC.

<PAGE>

Investments by IDS Life


IDS Life must  invest  its assets in its  general  account  in  accordance  with
requirements  established  by  applicable  state laws  regarding  the nature and
quality of investments that life insurance companies may make and the percentage
of their assets that they may commit to any particular  type of  investment.  In
general,  these laws permit investments,  within specified limits and subject to
certain qualifications, in federal, state, and municipal obligations,  corporate
bonds,   asset-backed  securities  preferred  and  common  stocks,  real  estate
mortgages,  real estate and certain other investments.  All claims by purchasers
of the  contracts,  and other general  account  products,  will be funded by the
general account.

We intend to construct  and manage the  investment  portfolio  relating to these
market  value  annuity  contracts  using a  strategy  known  as  "immunization."
Immunization  seeks to lock in a defined return on the pool of assets versus the
pool of  liabilities  over a  specified  time  horizon.  Since the return on the
assets  versus the  liabilities  is locked in, it is "immune"  to any  potential
fluctuations in interest rates during the given time. We achieve immunization by
constructing  a portfolio of assets with a price  sensitivity  to interest  rate
changes (i.e.,  price duration) that is essentially  equal to the price duration
of the corresponding  portfolio of liabilities.  Portfolio immunization provides
us with flexibility and efficiency in creating and managing the asset portfolio,
while still assuring safety and soundness for funding liability obligations.

Our  investment  strategy  will  incorporate  the  use  of  a  variety  of  debt
instruments  having price durations  tending to match the applicable  guaranteed
interest periods. These instruments include, but are not necessarily limited to,
the following:


o    Securities issued by the U.S. government or its agencies or
     instrumentalities, which issues may or may not be guaranteed by the U.S.
     government;

o    Debt  securities  that have an investment  grade,  at the time of purchase,
     within the four highest grades assigned by the nationally recognized rating
     agencies or are rated in the two highest grades by the National Association
     of Insurance Commissioners;

o    Debt instruments that are unrated, but which are deemed by IDS Life to have
     an investment quality within the four highest grades;

o    Other debt instruments,  which are rated below investment grade, limited to
     15% of assets at the time of purchase; and

o    Real  estate  mortgages,  limited  to 30% of  portfolio  assets at the time
     of acquisition.

In addition,  options and futures  contracts on fixed income  securities will be
used  from time to time to  achieve  and  maintain  appropriate  investment  and
liquidity characteristics on the overall asset portfolio.

While this information  generally describes our investment strategy,  we are not
obligated to follow any particular strategy except as may be required by federal
law and Minnesota and other state insurance laws.

Selected financial data


You  should  read the  following  selected  financial  data for IDS Life and its
subsidiaries in conjunction with the consolidated financial statements and notes
included in the prospectus beginning on page __.


<PAGE>

<TABLE>
<CAPTION>



                                                        Years ended Dec. 31, (thousands)
                                       1999           1998           1997           1996            1995
<S>                                <C>            <C>            <C>            <C>            <C>

Premiums                           $              $   229,430    $    206,494   $    182,921   $    161,530
Net investment income                               1,986,485       1,988,389      1,965,362      1,907,309
Net realized (loss) on                                  6,902             860           (159)        (4,898)
investments
Other                                                 785,022         682,618        574,341        472,035
Total revenues                     $              $ 3,007,839    $  2,878,361   $  2,722,465   $  2,535,976
Income before income taxes         $              $   775,792    $    680,911   $    621,714   $    560,782
Net income                                            540,111    $    474,247   $    414,576   $    364,940
Total assets                       $              $  56,550,563  $ 52,974,124    $47,305,981    $42,900,078
</TABLE>


Management's  discussion and analysis of  consolidated  financial  condition and
results of operations. Directors and executive officers


To be included in amendment.

The members of the Board of Directors  and the principal  executive  officers of
IDS Life,  together with the  principal  occupation of each during the last five
years, are as follows:

Directors*

David R. Hubers
Born in 1943

Director since September  1989;  president and chief  executive  officer,  AEFC,
since August 1993,  and director  since  January  1984.  Senior vice  president,
Finance and chief financial officer, AEFC, from January 1984 to August 1993.

Richard W. Kling
Born in 1940

Director  since  February  1984;  president  since  March 1994.  Executive  vice
president,  Marketing and Products from January 1988 to March 1994.  Senior vice
president,  AEFC,  since May 1994.  Director of IDS Life Series  Fund,  Inc. and
member of the board of managers and president of IDS Life Variable Annuity Funds
A and B.

Paul F. Kolkman
Born in 1946

Director  since May 1984;  executive  vice  president  since  March  1994;  vice
president,  Finance from May 1984 to March 1994;  vice  president,  AEFC,  since
January 1987. Vice president and chief actuary of IDS Life Series Fund, Inc.

Paula R. Meyer
Born in 1954

Director and executive vice president  since 1998;  Vice  President,  AEFC since
1998;  Piper Capital  Management  (PCM) President from October 1997 to May 1998;
PCM Director of Marketing from June 1995 to October 1997; PCM Director of Retail
Marketing from December 1993 to June 1995.

<PAGE>

James A. Mitchell
Born in 1941

Chairman  of the board  since  March  1994;  director  since  July  1984;  chief
executive officer from November 1986 to March 1999;  president from July 1984 to
March 1994; executive vice president,  AEFC, since March 1994;  director,  AEFC,
since July 1984; senior vice president, AEFC, from July 1984 to March 1994.

Barry J. Murphy
Born in 1951

Director and executive vice president,  Client Service, since March 1994; senior
vice president,  AEFC,  since May 1994;  senior vice  president,  Travel Related
Services  (TRS),  a subsidiary of American  Express  Company,  from July 1992 to
April 1994; vice president, TRS, from November 1989 to July 1992.

Stuart A. Sedlacek
Born in 1957

Director  since  1994,  executive  vice  president  since 1998;  executive  vice
president,  Assured  Assets from March 1994 to 1998;  senior vice  president and
chief financial officer, AEFC, since 1998; vice president,  AEFC, from September
1988 to 1998.

Officers other than directors*

Timothy V. Bechtold
Born in 1953

Executive vice president,  Risk Management  Products since 1995; vice president,
Risk  Management,  AEFC  since  1995;  and  vice  president,  Insurance  Product
Development from 1989 to 1995.

Mark W. Carter
Born in 1954

Executive vice president,  Marketing since 1997; senior vice president and chief
marketing  officer,  AEFC since 1997;  vice  president of TVSM Inc. from 1996 to
1997; and regional vice president and general  manager of ADVO Inc. from 1991 to
1996.

Lorraine R. Hart
Born in 1951

Vice president,  Investments since 1992; vice president,  Insurance Investments,
AEFC since 1989; and vice president,  Investments, IDS Certificate Company since
1994.

Jeffrey S. Horton
Born in 1961

Vice president and treasurer  since December 1997;  vice president and corporate
treasurer, AEFC, since December 1997; controller,  American Express Technologies
- - Financial Services,  AEFC, from July 1997 to December 1997;  controller,  Risk
Management  Products,  AEFC, from May 1994 to July 1997; director of finance and
analysis, Corporate Treasury, AEFC, from June 1990 to May 1994.

Pamela J. Moret
Born in 1956

Executive vice president,  Variable Assets since 1997; vice president,  Variable
Assets, AEFC since 1997; vice president,  Retail Service Group of AEFC from 1996
to 1997; and vice president, Communications, AEFC from 1993 to 1996.

William A. Stoltzmann
Born in 1948

Vice  president,  general  counsel and secretary  since 1989; vice president and
assistant general counsel, AEFC, since November 1985.

Philip C. Wentzel
Born in 1961

Vice  president  and  controller  since 1998;  vice  president - Finance,  Risk
Management  Products,  AEFC since 1997; and director of financial  reporting and
analysis from 1992 to 1997.


*The  address  for all of the  directors  and  principal  officers  is:  200 AXP
Financial Center, Minneapolis, MN 55474.


<PAGE>

Executive compensation

Executive officers of IDS Life also may serve one or more affiliated  companies.
The  following  table  reflects cash  compensation  paid to the five most highly
compensated  executive  officers  as a group for  services  rendered in the most
recent  calendar year to IDS Life and its  affiliates.  The table also shows the
total cash compensation paid to all executive  officers of IDS Life, as a group,
who were executive officers at any time during the most recent calendar year.

<TABLE>
<CAPTION>
<S>                                      <C>                                               <C>

Name of individual or number in group                                                      Cash
                                         Position held                                     compensation
- ---------------------------------------- ------------------------------------------------- ------------------
Five most highly compensated executive                                                     $
officers as a group:


James A. Mitchell                        Chairman of the Board and Chief Executive
                                         Officer

Pamela J. Moret                          Exec. Vice President, Variable Assets

Barry J. Murphy                          Exec. Vice President, Client Service

Stuart A. Sedlacek                       Executive Vice President

Lorraine Hart                            Vice President, Investments

All executive officers as a group (10)

</TABLE>

Security ownership of management

IDS Life's directors and officers do not beneficially own any outstanding shares
of stock of IDS  Life.  All of the  outstanding  shares of stock of IDS Life are
beneficially owned by its parent,  American Express Financial  Corporation.  The
percentage  of shares of American  Express  Financial  Corporation  owned by any
director,  and by all  directors  and officers of IDS Life as a group,  does not
exceed 1% of the class outstanding.

Legal proceedings
A number of  lawsuits  have been  filed  against  life and  health  insurers  in
jurisdictions in which IDS Life and AEFC do business  involving  insurers' sales
practices,  alleged agent misconduct,  failure to properly  supervise agents and
other matters. IDS Life and AEFC, like other life and health insurers, from time
to time are  involved  in such  litigation.  On  December  13,  1996,  an action
entitled Lesa Benacquisto and Daniel  Benacquisto vs. IDS Life Insurance Company
and American  Express  Financial  Corporation  was commenced in Minnesota  state
court.  The action was brought by individuals  who replaced an existing IDS Life
insurance policy with a new IDS Life policy. The plaintiffs purport to represent
a class  consisting of all persons who replaced  existing IDS Life policies with
new policies from and after January 1, 1985. The complaint puts at issue various
alleged sales practices and  misrepresentations,  alleged  breaches of fiduciary
duties and alleged  violations  of consumer  fraud  statutes.  IDS Life and AEFC
filed an answer to the complaint on February 18, 1997,  denying the allegations.
A second action,  entitled Arnold Mork, Isabella Mork, Ronald Melchart and Susan
Melchart  vs.  IDS  Life  Insurance   Company  and  American  Express  Financial
Corporation  was  commenced in the same court on March  21,1997.  In addition to
claims that are included in the Benacquisto  lawsuit, the second action includes
an allegation of improper  replacement of an existing IDS Life annuity contract.
A subsequent  class action,  Richard  Thoresen and Elizabeth  Thoresen vs. AEFC,
American  Partners Life Insurance  Company,  American  Enterprise Life Insurance
Company,  American Centurion Life Assurance Company,  IDS Life Insurance Company
and IDS Life  Insurance  Company  of New York,  was  filed in the same  court on
October 13, 1998 alleging that the sale of annuities

<PAGE>

in tax-deferred  contributory  retirement  investment plans (e.g. IRAs) was done
through deceptive marketing practices, which IDS Life denies. Plaintiffs in each
of the above  actions  seek  damages in an  unspecified  amount and also seek to
establish a claims  resolution  facility  for the  determination  of  individual
issues.



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


<PAGE>

Experts

Ernst & Young LLP, independent auditors, have audited the consolidated financial
statements of IDS Life Insurance Company at Dec. 31, 1998 and 1997, and for each
of the three  years in the period  ended Dec.  31,  1998,  as set forth in their
report.  We've included our consolidated  financial statements in the prospectus
and elsewhere in the  registration  statement in reliance on Ernst & Young LLP's
report, given on their authority as experts in accounting and auditing.

<PAGE>

Appendix A

Partial surrender illustration

Involving a surrender charge and a market value adjustment

Annuity assumptions:
Single payment             $10,000
Guarantee period           10 years
Guarantee rate (ig)        6% effective annual yield

                                                            End of contract year
        Contract                   Surrender                accumulation values
          year                     charge %                   if no surrenders
- -------------------------- -------------------------- --------------------------

            1                         8%                        $10,600.00
            2                         7                          11,236.00
            3                         6                          11,910.16
            4                         5                          12,624.77
            5                         4                          13,382.26
            6                         3                          14,185.19
            7                         2                          15,036.30
            8                         1                          15,938.48
            9                         0                          16,894.79
           10                         0                          17,908.48

Partial surrender assumptions:

On the first day of your 4th contract year you request a partial surrender of:

Example  I -  $2,000  of your  accumulation  value  Example  II - A  $2,000  net
surrender check

You may  surrender  10% of  $11,910.16  (end of 3rd contract  year  accumulation
value) without surrender charge but subject to a market value adjustment -- this
is $1,191.02

The  excess  market  adjusted  value  surrendered  is  subject to both a 5% (4th
contract year) surrender charge and a market value adjustment.

The current rate (ic) for applicable new sales and renewals = 5.5%

The number of full years left in your guarantee period (N) = 7

The number of fractional years left in your guarantee period (t) = 0

<PAGE>

Example I - $2,000 of accumulation value surrendered

What will be your market value adjustment amount?

The market adjusted value of your $2,000 partial surrender will be:

                     Renewal value of accumulation value surrendered
                                  (1 + ic + .0025)(N+t)

         =    $2,000 (1 + ig)7
              (1 + ic + .0025)7

         =    $2,000 (1.06)7
                   (1.0575)7

         =    $2,033.33

The market value  adjustment = the market  adjusted value  surrendered  less the
accumulation value surrendered

         $2,033.33      -    $2,000     =   $33.33

(NOTE: This market value adjustment is positive. In other cases the market value
adjustment may be negative.)

What will be your surrender charge amount?

The surrender  charge will be 5% multiplied by the excess of the market adjusted
value over the  accumulation  value that may be  surrendered  without  surrender
charge:

         ($2,033.33 - $1,191.02) x .05 = $42.12

What net amount will you receive?

Your contract's  accumulation value will decrease by $2,000 and we will send you
a check for:

Accumulation value surrendered                 $2,000.00
Market value adjustment                            33.33
Less surrender charge                             (42.12)
- --------------------------------------------------------
Net surrender amount                           $1,991.21

Example II - $2,000 net surrender check requested

What will be the accumulation value surrendered?

Tell us if you  want a  specific  net  surrender  check  amount.  We  will  work
backwards  using an involved  formula to determine how much  accumulation  value
must be surrendered to result in a net check to you for a specific amount. For a
$2,000 net check to you, the formula results in $2,009.09 of accumulation  value
to be surrendered.

<PAGE>

What will be your market value adjustment amount?

The market adjusted value is:

         Renewal value of accumulation value surrendered
                            (1 + ic + .0025)(N+t)

         =    $2,009.09 (1 + ig)7
              (1 + ic + .0025)7

         =    $2,009.09 (1.06)7
                     (1.0575)7

         =    $2,042.58

The market value  adjustment = the market  adjusted value  surrendered  less the
accumulation value surrendered

         $2,042.58      -    $2,009.09      =    $33.49

(NOTE: This market value adjustment is positive. In other cases the market value
adjustment may be negative.)

What will be your surrender charge amount?

The surrender  charge will be 5% multiplied by the excess of the market adjusted
value over the  accumulation  value that may be  surrendered  without  surrender
charge:

         ($2,042.58 - $1,191.02) x .05 = $42.58

What net amount will you receive?

Your contract's  accumulation  value will decrease by $2,009.09 and we will send
you a check for:

Accumulation value surrendered                 $2,009.09
Market value adjustment                            33.49
Less surrender charge                             (42.58)
- --------------------------------------------------------
Net surrender amount                           $2,000.00

<PAGE>

Appendix B

Market value adjustment illustration

Annuity assumptions:
Single payment             $50,000
Guarantee period           10 years
Guarantee rate             6% effective annual yield

Market  adjustment  assumptions:  These  examples  show  how  the  market  value
adjustment  may affect your contract  values.  The  surrenders in these examples
occur one year after the contract date. There are no previous surrenders.

The  accumulation  value at the end of one year is $53,000.  If there aren't any
surrenders, the renewal value at the end of the 10 year guarantee period will be
$89,542.38.

We base the market value adjustment on the rate we are crediting (at the time of
your  surrender) on new contracts with the same length  guarantee  period as the
time remaining in your guarantee  period.  After one year, you have 9 years left
of your 10 year guarantee period.

Example I shows a downward market value  adjustment.  Example II shows an upward
market value  adjustment.  These  examples do not show the surrender  charge (if
any) which would be  calculated  separately  after the market value  adjustment.
Surrender charge calculations are shown in Appendix A.

Market adjusted value formula:

Market adjusted value        =             (Renewal value)
                                        (1 + ic + .0025)(N+t)

Renewal value       -    The accumulation value at the end of the current
                         guarantee period

ic                  -    The current interest rate offered for new contract
                         sales and renewals for the number of years remaining
                         in the guarantee period

N                   -    The number of complete contract years to the end of the
                         current guarantee period

t                   -    The fraction of the contract year remaining to the end
                         of the contract year

Example I - Downward market value adjustment

A surrender  results in a downward  market value  adjustment when interest rates
have  increased.  Assume  after 1  year,  we are now  crediting  6.5%  for a new
contract with a 9 year  guarantee  period.  If you fully  surrender,  the market
adjusted value would be:

         Renewal value
         (1 + ic + .0025)(N+t)

         =          $89,542.38
              (1 + .065 + .0025)9

         =    $49,741.36

The market value adjustment is a $3,258.64 reduction of the accumulation value:

         ($3,258.64)     =   $49,741.36    -   $53,000



<PAGE>


If you  surrendered  half of your contract  instead of all, the market  adjusted
value of the surrendered portion would be one-half that of the full surrender:

                          $44,771.19
$24,870.68      =   (1 + .065 + .0025)9

Example II - Upward market value adjustment

A surrender  results in an upward market value  adjustment  when interest  rates
have  decreased  more than .25%.  Assume after 1 year, we are now crediting 5.5%
for a new contract with a 9 year guarantee period.
If you fully surrender, the market adjusted value would be:

         Renewal value
         (1 + ic + .0025)(N+t)

         =         $89,542.38
              (1 + .055 + .0025)9

         =    $54,138.38

The market value adjustment is a $1,138.38 increase of the accumulation value:

         $1,138.38       =   $54,138.38    -   $53,000

If you  surrendered  half of your contract  instead of all, the market  adjusted
value of the surrendered portion would be one-half that of the full surrender:

                           $44,771.19
$27,069.19      =   (1 + .055 + .0025)9

<PAGE>


                                    PART II.

                     INFORMATION NOT REQUIRED IN PROSPECTUS

Item 13.       Other Expenses of Issuance and Distribution.

        The expenses of the issuance and  distribution  of the  interests in the
IDS Life Account MGA of IDS Life Insurance Company to be registered,  other than
commissions on sales of the Contracts, are to be borne by the registrant.

Item 14.       Indemnification of Directors and Officers

        Section  300.083 of Minnesota  Law  provides in part that a  corporation
organized  under  such  law  shall  have  power to  indemnify  anyone  made,  or
threatened to be made, a party to a threatened, pending or completed proceeding,
whether civil or criminal, administrative or investigative, because he is or was
a director or officer of the corporation,  or served as a director or officer of
another corporation at the request of the corporation. Indemnification in such a
proceeding  may  extend  to  judgments,  penalties,  fines and  amounts  paid in
settlement,  as well as to reasonable  expenses,  including  attorneys' fees and
disbursements.  In a civil proceeding, there can be no indemnification under the
statute,  unless it appears that the person seeking indemnification has acted in
good faith and in a manner he  reasonably  believed to be in, or not opposed to,
the best  interests  of the  corporation  and its  shareholders  and unless such
person has received no improper personal benefit; in a criminal proceeding,  the
person seeking indemnification must also have no reasonable cause to believe his
conduct was unlawful.

        Article IX of the By-laws of IDS Life  Insurance  Company  requires  IDS
Life  Insurance  Company  to  indemnify  directors  and  officers  to the extent
indemnification is permitted as stated by the preceding paragraph,  and contains
substantially the same language as the above-mentioned Section 300.083.

        Article IX, paragraph (2), of the By-laws of IDS Life Insurance  Company
provides as follows:

        "Section 2. The  Corporation  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."

        The parent company of IDS Life Insurance  Company maintains an insurance
policy which  affords  liability  coverage to directors and officers of IDS Life
Insurance Company while acting in that capacity. IDS Life Insurance Company pays
its proportionate share of the premiums for the policy.

<PAGE>

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

Item 15.       Recent Sales of Unregistered Securities

               None

Item 16.       Exhibits and Financial Statement Schedules

(a)     Exhibits

1.- 2. Not applicable.

3.1  Copy of Certificate of  Incorporation  of IDS Life Insurance  Company filed
     electronically  as  Exhibit  3.1  to  Post-Effective  Amendment  No.  5  to
     Registration Statement No. 33-28976 is incorporated herein by reference.

3.2  Copy  of  the  Amended   By-laws  of  IDS  Life  Insurance   Company  filed
     electronically  as  Exhibit  3.2  to  Post-Effective  Amendment  No.  5  to
     Registration Statement No. 33-28976 is incorporated herein by reference.

3.3  Copy of Resolution of the Board of Directors of IDS Life Insurance Company,
     dated May 5, 1989,  establishing IDS Life Account MGA filed  electronically
     as Exhibit 3.3 to Post-Effective  Amendment No. 5 to Registration Statement
     No. 33-28976 is incorporated herein by reference.

4.1  Copy of Non-tax  qualified  Group  Annuity  Contract,  Form  30363C,  filed
     electronically  as  Exhibit  4.1  to  Post-Effective  Amendment  No.  5  to
     Registration Statement No. 33-28976 is incorporated herein by reference.

4.2  Copy of Non-tax  qualified Group Annuity  Certificate,  Form 30360C,  filed
     electronically  as  Exhibit  4.2  to  Post-Effective  Amendment  No.  5  to
     Registration Statement No. 33-28976 is incorporated herein by reference.

4.3  Copy of  Endorsement  No.  30340C-GP to the Group  Annuity  Contract  filed
     electronically  as  Exhibit  4.3  to  Post-Effective  Amendment  No.  5  to
     Registration Statement No. 33-28976 is incorporated herein by reference.

4.4  Copy of  Endorsement  No.  30340C to the Group  Annuity  Certificate  filed
     electronically  as  Exhibit  4.4  to  Post-Effective  Amendment  No.  5  to
     Registration Statement No. 33-28976 is incorporated herein by reference.

<PAGE>

4.5  Copy  of  Tax  qualified  Group  Annuity  Contract,   Form  30369C,   filed
     electronically  as  Exhibit  4.5  to  Post-Effective  Amendment  No.  10 to
     Registration Statement No. 33-28976 is incorporated herein by reference.

4.6  Copy  of Tax  qualified  Group  Annuity  Certificate,  Form  30368C,  filed
     electronically  as  Exhibit  4.6  to  Post-Effective  Amendment  No.  10 to
     Registration Statement No. 33-28976 is incorporated herein by reference.

4.7  Copy of Group IRA Annuity Contract,  Form 30372C,  filed  electronically as
     Exhibit 4.7 to  Post-Effective  Amendment No. 10 to Registration  Statement
     No. 33-28976 is incorporated herein by reference.

4.8  Copy of Group IRA Annuity Certificate, Form 30371C, filed electronically as
     Exhibit 4.8 to  Post-Effective  Amendment No. 10 to Registration  Statement
     No. 33-28976 is incorporated herein by reference.

4.9  Copy of Non-tax qualified  Individual Annuity Contract,  Form 30365D, filed
     electronically  as  Exhibit  4.9  to  Post-Effective  Amendment  No.  10 to
     Registration Statement No. 33-28976 is incorporated herein by reference.

4.10 Copy of Endorsement  No. 30379 to the Individual  Annuity  Contract,  filed
     electronically  as  Exhibit  4.10 to  Post-Effective  Amendment  No.  10 to
     Registration Statement No. 33-28976 is incorporated herein by reference.

4.11 Copy of Tax  qualified  Individual  Annuity  Contract,  Form 30370C,  filed
     electronically  as  Exhibit  4.11 to  Post-Effective  Amendment  No.  10 to
     Registration Statement No. 33-28976 is incorporated herein by reference.

4.12 Copy of Individual IRA Annuity Contract,  Form 30373C, filed electronically
     as  Exhibit  4.12  to  Post-Effective  Amendment  No.  10  to  Registration
     Statement No. 33-28976 is incorporated herein by reference.

5.   Copy of Opinion of Counsel regarding  legality of Contracts,  dated Oct. 3,
     1990, filed  electronically as Exhibit 5 to Post-Effective  Amendment No. 5
     to Registration Statement No. 33-28976 is incorporated herein by reference.

6.-20. Not applicable.

21.  Copy  of  List  of  Subsidiaries  filed  electronically  as  Exhibit  22 to
     Post-Effective  Amendment No. 8 to  Registration  Statement No. 33-28976 is
     incorporated herein by reference.

22.  Not applicable.

23.  Consent of Independent Auditors, will be filed by amendment.

24.1 Power of Attorney,  dated August 19, 1997, filed  electronically as Exhibit
     24.1 to  Post-Effective  Amendment  No. 10 to  Registration  Statement  No.
     33-28976 is incorporated herein by reference.


<PAGE>

24.2 Power of Attorney,  dated April 9, 1998,  filed  electronically  as Exhibit
     24.2 to  Post-Effective  Amendment  No. 10 to  Registration  Statement  No.
     33-28976 is incorporated herein by reference.

25.-27. Not applicable.

(b) Financial Statement Schedules will be filed by amendment.

        Report of independent Auditors will be filed by amendment.

Item 17.       Undertakings

A.     The Registrant undertakes:

         (1)      to file,  during any period in which offers or sales are being
                  made,  a   post-effective   amendment  to  this   Registration
                  Statement:

                  (i)      to include any prospectus required by Section 10(a)
                          (3) of the Securities Act of 1933,

                  (ii)     to  reflect  in the  prospectus  any  facts or events
                           arising after the effective date of the  Registration
                           Statement   (or  the   most   recent   post-effective
                           amendment  thereof)  which,  individually  or in  the
                           aggregate,  represent  a  fundamental  change  in the
                           information set forth in the Registration Statement,

                  (iii)    to include any material  information  with respect to
                           the plan of distribution not previously  disclosed in
                           the Registration  Statement or any material change to
                           such information in the Registration Statement,

         (2)      that, for the purpose of determining  any liability  under the
                  Securities  Act of 1933,  each such  post-effective  amendment
                  shall be deemed to be a new Registration Statement relating to
                  the  securities  offered  therein,  and the  offering  of such
                  securities  at that time may be deemed to be the initial  bona
                  fide offering thereof,

         (3)      that  all  post-effective  amendments  will  comply  with  the
                  applicable  forms,  rules and regulations of the Commission in
                  effect at the time such  post-effective  amendments are filed,
                  and

         (4)      to  remove  from  registration  by means  of a  post-effective
                  amendment any of the securities  being registered which remain
                  unsold at the termination of the offering.

B.     The 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, the Registrant  represents that it has complied with the
       provisions of paragraphs (1) - (4) of the no-action letter.


<PAGE>


                                   SIGNATURES

Pursuant to the  requirements  of the Securities Act of 1933, IDS Life Insurance
Company has duly caused this  Registration  Statement  to be signed on behalf of
the Registrant by the  undersigned,  thereunto  duly  authorized in this City of
Minneapolis, and State of Minnesota on the 10th day of March, 2000.

                                        IDS Life Insurance Company
                                               (Registrant)

                                        By IDS Life Insurance Company

                                        By /s/ James A. Mitchell*
                                               James A. Mitchell


Pursuant to the  requirements of the Securities Act of 1933,  this  Registration
Statement  has been  signed  below by the  following  persons in the  capacities
indicated on the 10th day of March, 2000.

Signature                            Title


 /s/ Richard W. Kling                Director, President and Chief Executive
     Richard W. Kling                Officer


/s/  Jeffrey S. Horton**             Vice President and Treasurer
     Jeffrey S. Horton

/s/  David R. Hubers*                Director
     David R. Hubers

/s/  Paul F. Kolkman*                Director
     Paul F. Kolkman

/s/  James A. Mitchell*              Director
     James A. Mitchell

/s/  Barry J. Murphy*                Director
     Barry J. Murphy

/s/  Stuart A. Sedlacek*             Director
     Stuart A. Sedlacek

/s/  Philip C. Wentzel**             Vice President and Controller
     Philip C. Wentzel


<PAGE>

*Signed   pursuant  to  Power  of  Attorney   dated  August  19,   1997,   filed
electronically  as Exhibit 24.1 for IDS Life Insurance Company (IDS Life Account
MGA) to Post-Effective  Amendment No. 10 to Registration  Statement No. 33-28976
and incorporated herein by reference.

**Signed pursuant to Power of Attorney dated April 9, 1998, filed electronically
as  Exhibit  24.2 for IDS Life  Insurance  Company  (IDS  Life  Account  MGA) to
Post-Effective  Amendment  No. 10 to  Registration  Statement  No.  33-28976 and
incorporated herein by reference.

By:



/s/ Bruce A. Kohn
    Bruce A. Kohn



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