IDS LIFE VARIABLE LIFE SEPARATE ACCOUNT
N-8B-2, 1995-09-22
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PAGE 1
   
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C.  20549





AMENDMENT NO 5 TO
FORM N-8B-2
FILE NO. 811-4298




DATED September 21, 1995





REGISTRATION STATEMENT OF UNIT INVESTMENT TRUSTS
WHICH ARE CURRENTLY ISSUING SECURITIES





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



IDS Life Variable Life
Separate Account










Issuer of Periodic Payment Plan Certificates







C/O IDS Life Insurance Company
IDS Tower 10
Minneapolis, Minnesota  55440-0010
    <PAGE>
PAGE 2                    I.

ORGANIZATION AND GENERAL INFORMATION

1.  (a)  Furnish name of the trust and Internal Revenue Service
         Employer Identification Number.  

         IDS Life Variable Life Separate Account (Hereinafter
         called "the Variable Account").

         The Variable Account does not have an IRS Employer
         Identification Number.

    (b)  Furnish title of each class or series of securities
         issued by the trust.

         Single Premium Variable Life Insurance Policy
         Flexible Premium Variable Universal Life Insurance
         Policy
   
         Flexible Premium Survivorship Life Insurance Policy
    
2.  Furnish name and principal business address and zip code and
    the Internal Revenue Service Employer Identification Number
    of each depositor of the trust.

    IDS Life Insurance Company ("IDS Life)
    IDS Tower 10
    Minneapolis, MN 55440-0010
    IRS Employer #41 082 3832

3.  Furnish name and principal business address and zip code and
    the Internal Revenue Service Employer Identification Number
    of each custodian or trustee of the trust indicating for
    which class or series of securities each custodian or trustee
    is acting.

    Not applicable.

4.  Furnish name and principal business address and zip code and
    the Internal Revenue Service Employer Identification Number
    of each principal underwriter currently distributing
    securities of the trust.

    As of the date of the original registration statement, no
    policies were being distributed.  IDS Life is the exclusive
    distributor of the policies currently being distributed and
    may be deemed to be the principal underwriter thereof.

5.  Furnish name of state or other sovereign power, the laws of
    which govern with respect to the organization of the trust.

    Minnesota

6.  (a) Furnish the dates of execution and termination of any
    indenture or agreement currently in effect under the terms of
    which the trust was organized and issued or proposes to issue
    securities.<PAGE>
PAGE 3
    The Variable Account was established as a separate account of
    IDS Life pursuant to a resolution of the Board of Directors
    of IDS Life adopted on October 16, 1985.

    The Variable Account will continue in existence until its
    complete liquidation and the distribution of its assets to
    the persons entitled to receive them.

    (b)  Furnish the dates of execution and termination of any
         indenture or agreement currently in effect pursuant to
         which the proceeds of payments on securities issued or
         to be issued by the trust are held by the custodian or
         trustee.

         There is no separate Custodian Agreement.  The assets
         of the Variable Account will be held by IDS Life as a
         separate account for the exclusive benefit of Owners
         having an interest therein.

7.  Furnish in chronological order the following information with
    respect to each change of name of the trust since January 1,
    1930.  If the name has never been changed, so state.

    The name of the Variable Account has never been changed. 
    However, the Variable Account is a Successor Issuer to IDS
    Life Accounts P, Q, R, S, and T which previously filed this
    Registration Statement with the Commission on May 10, 1985.

8.  State the date on which the fiscal year of the trust ends.

    The fiscal year of the Variable Account ends December 31.

Material Litigation

9.  Furnish a description of any pending legal proceedings,
    material with respect to the security holders of the trust by
    reason of the nature of the claim or the amount thereof, to
    which the trust, the depositor, or the principal underwriter
    is a party or of which the assets of the trust are the
    subject, including the substance of the claims involved in
    such proceedings and the title of the proceeding.  Furnish a
    similar statement with respect to any pending administrative
    proceeding commenced by a governmental authority or any such
    proceeding or legal proceeding known to be contemplated by a
    governmental authority.  Include any proceeding which,
    although immaterial itself, is representative of, or one of,
    a group which in the aggregate is material.

    The Variable Account is a not party to any legal or
    administrative proceedings.  IDS Life is engaged in
    litigation of various kinds which is, in its judgment, not of
    material importance.

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PAGE 4
                          II.

GENERAL DESCRIPTION OF THE TRUST AND SECURITIES OF THE TRUST

General Information Concerning the Securities of the Trust and the
Rights of Holders

10. Furnish a brief statement with respect to the following
    matters for each class or series of securities issued by the
    trust:

    (a)  Whether the securities are of the registered or bearer
         type.

         The Policies are of the registered type insofar as each
         Policy is personal to the Owner, the records concerning
         the Owner are maintained by IDS Life, and ownership
         cannot be transferred except upon notice to IDS Life.

    (b)  Whether the securities are of the cumulative or
         distributive type.

         The Policies are of the cumulative type, providing for
         no distribution of income, dividends or capital gain,
         except in connection with surrender or payment of
         proceeds upon the death of the Insured.

         The Policy is non-participating.

    (c)  The rights of security holders with respect to
         withdrawal or redemption.

         Policy 1

         The Owner may obtain a refund of the entire amount of
         any premiums paid under the Policy without limitation
         as to amount or payment of any fee or penalty, provided
         that the Owner returns the Policy, with a written
         request for cancellation, to the Company or its
         representative by the latest of:

         a)   the 10th day after receipt of the Policy by the
              Owner; or

         b)   within 10 days after IDS Life mails or personally
              delivers a written notice of withdrawal right; or

         c)   the 45th day after the application is signed.

         In such event, the Company will refund the premium that
         was paid within seven days after receipt of the policy.

         The Owner may surrender the Contract subject to the
         following rules.  A request for surrender must be made
         in writing by the Owner to IDS Life at its Home Office. 
         IDS Life may require that the Policy be returned to it. 
         IDS Life will compute the Surrender Value as of the end<PAGE>
PAGE 5
         of the Valuation Period during which the surrender
         request is received at Its Home Office.  The Surrender
         Value of the Variable Account will be paid within seven
         days after the Owner's written request is received by
         IDS Life at its Home Office, however, IDS Life reserves
         the right to defer any payment of Surrender Value of
         the Variable Account (1) which derives from a Premium
         Payment made by a check which has not cleared the
         banking system (good payment has been collected), or
         (2) if (a) the New York Stock Exchange is closed (other
         than customary weekend and holiday closing), (b)
         trading on the Exchange is restricted; (c) an emergency
         exists such that it is not reasonably practical to
         dispose of securities held in the Accounts or to
         determine the value of the Accounts' net assets; or (d)
         the Securities and Exchange Commission by order so
         permits for the protection of security holders. 
         Conditions described in (b) and (c) will be decided by
         or in accordance with rules of the Securities and
         Exchange Commission.

         No sales charge is deducted from the premium payments. 
         However, IDS Life will use a Surrender Charge to help
         it recover certain expenses relating to the sale of the
         Policy, including commissions paid to sales personnel,
         other promotional and selling expenses, and
         underwriting and issue expenses.  The Surrender Charges
         are shown on the Policy Data page of the Policy.  They
         apply for the first 8 years after the Policy is issued.

         At the time of issue, a schedule of Surrender Charges
         varying by policy duration is assigned to the Policy. 
         These Surrender Charges are a percentage of the Policy
         Value at the time of Surrender.  The charge will never
         exceed 9% of the single premium paid by the Owner.

         Policy 2

         The Policy may be returned for a full refund of the
         premiums paid, for any reason, if it is returned by the
         Owner to IDS Life or its representative, with a written
         request for cancellation, by the latest of: (a) the
         10th day after it is received by the Owner; or b) the
         10th day after IDS Life mails or personally delivers a
         written notice of withdrawal right; or c) the 45th day
         after the application is signed.  Immediately on such
         mailing or delivery, the Policy will be considered void
         from the start.

         The Policy may be totally surrendered for its Cash
         Surrender Value.  This is the Policy Value less
         indebtedness and less any applicable Surrender Charges.

         The Owner may surrender the policy in whole or in part
         subject to the following rules.  A request for
         surrender may be made in writing by the owner to IDS 
<PAGE>
PAGE 6
         Life at its home office.  The Owner also may request a
         partial surrender by calling IDS Life.  Partial
         surrenders by telephone are limited to $50,000.  IDS
         Life has the authority to honor any telephone surrender
         request believed to be authentic.  IDS Life is not
         responsible for determining the authenticity of such
         calls.  A surrender request received before 3 p.m.
         Central time (which is 4 p.m. New York time) will be
         processed the same day.  If the call or written request
         is received after 3 p.m., the request will be processed
         the following business day.  IDS Life may require that
         the Policy be returned to it.  IDS Life will compute
         the cash surrender value of the Variable Account as of
         the end of the valuation period during which the
         surrender request is received at its home office.

         The cash surrender value will be paid within seven days
         after the Owner's written request is received by IDS
         Life at its home office, however IDS Life reserves the
         right to defer any payment of cash surrender value (1)
         which derives from a premium payment made by a check
         which has not cleared the banking system (good payment
         has been collected), or (2) if (a) the New York Stock
         Exchange is closed (other than customary weekend and
         holiday closings), (b) trading on the Exchange is
         restricted; (c) an emergency exists such that it is not
         reasonably practical to dispose of securities held in
         the Variable Account or to determine the value of the
         Variable Account's net assets; or (d) the SEC by order
         so permits for the protection of security holders. 
         Conditions described in (b) and (c) will be decided by
         or in accordance with rules of the SEC.  Any excess of
         the cash surrender value plus policy loans over the
         premium paid, would, upon surrender, generally be
         taxable to the Owner.  Any surrenders of the Policy
         Value from the Fixed Account may be postponed for up to
         6 months.  If IDS Life postpones payment more than 30
         days, interest at an annual rate of 3 percent will be
         paid on the amount surrendered for the period of
         postponement.

         During the first 10 policy years and during the first
         10 years following any requested increase in Specified
         Amount, IDS Life will make a Surrender Charge if the
         Owner surrenders the Policy or the Policy lapses.  The
         Surrender Charge has two parts - the Contingent
         Deferred Issue and Administrative Expense Charge.

         The maximum Contingent Deferred Sales Charge and the
         maximum Contingent Deferred Issue and Administrative
         Expense Charge for the Initial Specified Amount or any
         requested increase in Specified Amount will be
         determined on the Policy Date or on the effective date
         of any such requested increase, as the case may be.  In
         general, these maximum charges remain level for the 
<PAGE>
PAGE 7
         first five years in the relevant 10-year period, and
         then reduce in equal monthly increments until they
         become zero at the end of 10 years.

         The Surrender Charge on the Initial Specified Amount is
         the lesser of:

              1.   The amount shown in the Surrender Charge
                   Table on the policy data page of the
                   Policy, or

              2.   An amount equal to (a) plus (b) plus (c);
                   where (a) is 27.5% of premium payments up
                   to a maximum amount shown in -the policy,
                   (b) is 6.5% of all other premium payments,
                   and (c) is $4.00 in policy years 1-5, times
                   the number of thousands of dollars of
                   initial specified amount.  After year 5,
                   amount (c) decreases monthly, and will be
                   zero at the end of year 10.

         After 5 years, the maximum surrender charge decreases
         on a monthly basis at a rate of 20% per year.  For an
         increase in specified amount, the new surrender charge
         for the increase is the lesser of:

              1.   The amount shown in the table on the policy
                   data page of a policy that applies to the
                   increased specified amount, or

              2.   An amount equal to (a) plus (b); where (a)
                   is 6.5% of all premium payments
                   attributable to the increase and (b) is, in
                   the first five years following the
                   increase, $4.00 times the number of
                   thousands of dollars of the increase in the
                   specified amount.  After the fifth year
                   following the increase amount (b) decreases
                   monthly and will be zero at the end of the
                   tenth year following the increase.

         A charge of $25.00 (or 2 percent of the amount
         surrendered, if less) will be imposed for each partial
         surrender.

         For an Owner and or beneficiary to receive the
         favorable tax treatment accorded by Section 72, 101 and
         7702 of the Internal Revenue Code, the policy must
         initially qualify and continue to qualify as life
         insurance under applicable tax law.  To make sure that
         the policy continues to qualify.  IDS Life has reserved
         in the policy the rights:

         to decline to accept premium payments,

         to decline to change death benefit options,
<PAGE>
PAGE 8
         to decline to permit partial surrenders, and

         to decline to decrease the Specified Amount,

         that would cause the policy to fail to qualify as life
         insurance under applicable tax law.  IDS Life may also
         make changes in the policy or its riders or make
         payments from the policy to the extent it deems
         necessary to continue to qualify the policy as life
         insurance.

         Policy 3

         The Policy may be returned for any reason, and the
         owner will receive a full refund of all premiums paid. 
         To do so, the owner must mail or deliver the policy to
         IDS Life or their financial advisor, with a written
         request for cancellation, by the latest of:
   
         o    the 10th day after they have received it (15th
              day in Colorado, 20th day in North Dakota);
         o    the 10th day after IDS Life mails or personally
              delivers a written notice of withdrawal right
              (15th day in Colorado, 20th day in North Dakota);
              or
         o    the 45th day after they sign the application.
    
         On the date the request is postmarked or received, the
         policy will immediately be considered void from the
         start.

         If the owner surrenders the policy or the policy lapses
         during the first 15 policy years, a surrender charge
         will be assessed.  The surrender charge is a contingent
         deferred issue and administration expense charge.  It
         reimburses IDS Life for costs if issuing the policy,
         such as processing the application (primarily
         underwriting) and setting up computer records.  IDS
         Life does not expect to make a profit on this charge. 
         This charge is $4 per thousand dollars of initial
         specified amount.  It remains level during the first
         five policy years and then decreases monthly until it
         is zero at the end of 15 policy years.

         If the owner surrenders part of the value of their
         policy, they will be charged $25 (or 2% of the amount
         surrendered, if less).  This fee is guaranteed not to
         increase for the duration of the policy.  IDS Life does
         not expect to make a profit on this fee.

         The owner may surrender the policy in full or in part
         by written or telephone request.  A surrender request
         received before close of business will be processed the
         same day.  A request received after close of business
         will be processed the following business day.  IDS Life
         may require the owner return the policy.
<PAGE>
PAGE 9
         IDS Life will normally process the payment within seven
         days; however, it reserves the right to defer payment.

         IDS Life reserves the right to defer payments of cash
         surrender value, policy loans, or variable death
         benefits in excess of the specified amount if:

         o    the payments derive from a premium payment made
              by a check that has not cleared the banking
              system (good payment has not been collected);

         o    the NYSE is closed (other than customary weekend
              and holiday closings);

         o    in accordance with SEC rules, trading on the NYSE
              is restricted or, because of an emergency, it is
              not practical to dispose of securities held in
              the subaccount or determine the value of the
              subaccount's net assets.

         Any loans or surrenders from the fixed account may be
         delayed up to six months from the date we receive the
         request.  If IDS Life postpones the payment of
         surrender proceeds more than 30 days, it will pay the
         owner interest on the amount surrendered at an annual
         rate of 3% for the period of postponement.

         Total surrenders:  If the owner surrenders the policy
         totally, they will receive its cash surrender value --
         the policy value minus outstanding indebtedness and
         applicable surrender charges.  IDS Life will compute
         the value of each subaccount as of the end of the
         valuation period during which the owner's request is
         received.
   
         Partial surrenders:  After the first policy year, the
         owner may surrender any amount from $500 up to 85% of
         the policy's cash surrender value.  (Partial surrenders
         by telephone are limited to $50,000.)  The owner will
         be charged a partial surrender fee of $25 (or 2% of the
         amount surrendered if less).
    
         Allocation of partial surrenders:  Unless the owner
         specifies otherwise, IDS Life will make partial
         surrenders from the fixed account and subaccounts in
         proportion to their values at the end of the valuation
         period during which your request is received.  In
         determining these proportions, IDS Life first subtracts
         the amount of any outstanding indebtedness from the
         fixed account value.
       
    (d)  The rights of security holders with respect to
         conversion, transfer, partial redemption and similar
         matters.
<PAGE>
PAGE 10
         Policy 1

         The Owner may transfer all or a part of the Policy
         Value held in one or more of the Subaccounts of the
         Variable Account to another one or more of the
         Subaccounts.  Currently there are five Subaccounts of
         the Variable Account.  At the present time, IDS Life
         limits the number of transfers between Subaccounts to
         five per policy year.  Each such transfer will be made,
         without the imposition of any fee or charge, as of the
         end of the Valuation Period during which IDS Life
         receives a valid, complete transfer request.  The
         minimum transfer amount is $250 from a Subaccount or,
         if less, the entire Policy Value in the Subaccount from
         which the transfer is being made.  The transfer
         privileges may be suspended or modified by IDS Life at
         any time, but no such modification will be made without
         any necessary approval of the SEC.  Transfers may be
         made by the Owner instructing IDS Life in writing of
         his/her request to transfer the Policy Value to another
         Subaccount(s).

         Telephone Transfers.  The Owner may also request a
         transfer by calling IDS Life if IDS Life has received
         authorization to honor such requests by a completed
         authorization form supplied by IDS Life.  This
         authorization form gives IDS Life the authority to
         honor any telephone transfer request believed to be
         authentic.  IDS Life is not responsible for determining
         the authenticity of such calls.

         After the authorization is received by IDS Life, a
         written statement will be sent to the Owner confirming
         that the service is available.  It will also provide
         the Owner instructions on how to use the telephone
         transfer service.

         A transfer request received before 3:00 p.m.
         Minneapolis time will be processed the same day.  If
         the call is received after 3:00 p.m., the request will
         be processed the following business day.

         During the first two years after the Policy has been
         issued, the Owner has the right on one occasion to
         exchange the Policy for a Single Premium Whole Life
         Policy which provides for benefits that do not vary
         with the investment return of the Variable Account.

         The new policy's death benefit will be the same as the
         initial death benefit of the variable life policy.  It
         will also have the same date of issue.  IDS Life will
         not require evidence of the insured's insurability
         before an exchange.  The new policy will be issued at
         IDS Life's then standard insurance rates.  IDS Life
         will require that any policy loan plus accrued interest
         be repaid before the exchange.  There will be an
         adjustment in the Policy Values upon exchange.  If<PAGE>
PAGE 11
         investment performance of the Variable Account has been
         poor, the Owner may need to pay an additional premium. 
         If investment performance has been better than
         expected, the Owner may receive a refund of some Policy
         Value.  There may be Federal Income Tax Consequences
         from such a refund.  The adjustment therefore will
         reflect the investment performance of the variable life
         policy.  IDS Life has filed a description of the method
         it uses to calculate the adjustment with the Securities
         and Exchange Commission and the appropriate state
         insurance officials.

         Policy 2

         By written request, or other requests acceptable to IDS
         Life, the Owner may transfer all or part of the value
         of a subaccount to one or more of the other subaccounts
         or to the fixed account.  The amount transferred,
         however, must be at least 1) $250; or 2) the total
         value in the subaccount, if less.  Only five such
         transfers may be made in a policy year.  This
         limitation does not include automatic reallocations of
         Trust values.  Except as discussed in the following
         paragraph, each such transfer will be made without the
         imposition of any fee or charge, as of the end of the
         valuation period during which IDS Life receives a valid
         complete transfer request.  IDS Life may suspend or
         modify this transfer privilege at any time with any
         necessary approval of the Securities and Exchange
         Commission.  The Owner may also transfer from the fixed
         account to the subaccounts once a year but only on the
         policy anniversary or within 30 days after such policy
         anniversary.  If the Owner makes this transfer, he or
         she cannot transfer from the subaccounts back into the
         fixed account until the next policy anniversary.  IDS
         Life will waive this limitation once during the first
         two policy years if the Owner exercises the policy's
         Right to Exchange provision.  If IDS Life receives a
         written request within 30 days before the policy
         anniversary date, the transfer from the Fixed Account
         to the subaccounts will be effective on the anniversary
         date.  If IDS Life receives a written request within 30
         days after the policy anniversary date, the transfer
         from the Fixed Account to the subaccounts will be
         effective on the date IDS Life receives the request. 
         The minimum transfer amount is $250 or the Fixed
         Account value less indebtedness, if less.  The maximum
         transfer amount is the Fixed Account value, less
         indebtedness.  This transfer privilege may be suspended
         or modified by IDS Life at any time.

         The Owner also may request a transfer by calling IDS
         Life.  IDS Life has the authority to honor any
         telephone transfer request believed to be authentic. 
         IDS Life is not responsible for determining the
         authenticity of such calls.
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PAGE 12
         A transfer request received before 3 p.m. Central time
         (which is 4 p.m. New York time) will be processed the
         same day.  If a call or written request is received
         after 3 p.m. Central time, the request will be
         processed the following business day.

         In addition to written and phone requests, the owner
         can arrange to have policy value transferred from one
         account to another automatically.  The requirements
         are:

         o    Minimum automated transfer: $50

         o    Frequency: monthly, quarterly, semiannually or
              annually

         o    Only one automated transfer arrangement can be in
              effect at any time.  Policy values may be
              transferred to one or more subaccounts and the
              fixed account but can be transferred from only
              one account.

         o    The owner can start or stop this service by
              written request. The owner must allow seven days
              for IDS Life to change any instructions that are
              currently in place.

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

         o    If the owner has made a transfer from the fixed
              account to one or more subaccounts, the owner may
              not make a transfer from any subaccount back to
              the fixed account until the next policy
              anniversary.

         o    If the request is submitted with an application
              for a policy, it will not take effect until the
              policy is issued.

         o    If the value of the account from which policy
              value is being transferred is less than the $50
              minimum, the transfer arrangement will
              automatically be stopped.

         o    Automated transfers are subject to all other
              policy provisions and terms including provisions
              relating to the transfer of money between the
              fixed account and the subaccounts.

         After the first policy year, the Owner may also request
         to surrender up to 85 percent of the Policy's Cash
         surrender Value.  A fee of $25.00 is assessed for each
         partial surrender.  However, the fee will not exceed 2
         percent of the amount surrendered.  This charge is
         guaranteed not to increase for the duration of the<PAGE>
PAGE 13
         Policy.  The amount of any partial surrender must be at
         least $500.00.  Partial surrenders by telephone are
         limited to $50,000.

         Unless the Owner specifies a different allocation, IDS
         Life will make partial surrenders from the Fixed
         Account and the subaccounts of the Variable Account on
         a proportionate basis based upon the policy value. 
         These proportions will be determined at the end of the
         valuation period during which a request is received. 
         For purposes of determining these proportions, any
         outstanding loan amount is first subtracted from the
         Fixed account value.

         The Policy Value will be reduced by the amount of any
         partial surrender and partial surrender fee.  The Death
         Benefit will also be reduced by the amount of the
         partial surrender and partial surrender fee, or, if the
         Death Benefit is based on the applicable percentage of
         policy value, by an amount equal to the applicable
         percentage times the amount of the partial surrender.

         If Option 1 is in effect, the Specified Amount will be
         reduced by the amount of the partial surrender and
         partial surrender fee.  When increases in the Specified
         Amount have occurred previously, IDS Life will reduce
         the current Specified Amount by the amount of the
         partial surrender in the following order:

         (a)  the Specified Amount provided by the most recent
              increase;

         (b)  the next most recent increases successively; and

         (c)  the Specified Amount when the policy was issued.

         Thus, partial surrenders may affect the way in which
         the cost of insurance is calculated and the net amount
         at risk under the Policy.

         IDS Life does not allow a partial surrender if the
         Specified Amount after a partial surrender would be
         less than the Minimum Specified Amount.

         If Option 2 is in effect, a partial surrender does not
         affect the Specified Amount.

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

         During the first two years after the Policy has been
         issued, the owner has the right on one occasion to
         exchange the Policy for a Flexible Premium Adjustable<PAGE>
PAGE 14
         Whole Life Policy which provides for benefits that do
         not vary with the investment return of the Variable
         Account.  This will be accomplished by transferring all
         of the Policy Value in the Variable Account to the
         Fixed Account.

         If at any time during the first two policy years the
         Owner requests a transfer from the Variable Account to
         the Fixed Account and indicates that the transfer is in
         exercise of this conversion right, the transfer will
         not count against the five-transfers-per-year limit. 
         Also, any restrictions which may exist on transfers
         into the Fixed Account will be waived for this one
         time, if the Owner is exercising the conversion right. 
         At the time of such transfer, there is no effect on the
         Policy's Death Benefit, Specified Amount, net amount at
         risk, Rate Class(es) or issue age - only the method of
         funding the policy value under the Policy will be
         affected.

         If the Owner transfers all of the values in the
         Variable Account to the Fixed Account and indicates
         that this transfer is in exercise of this conversion
         right, IDS Life will automatically credit all future
         premium payments on the Policy to the Fixed Account
         unless the Owner requests a different allocation.

         Policy 3
   
         Effects of partial surrenders:

         o    The policy value will be reduced by the amount of
              the partial surrender and fee.

         o    The death benefit will be reduced by the amount
              of the partial surrender and fee, or, if the
              death benefit is based on the applicable
              percentage of policy value, by an amount equal to
              the applicable percentage times the amount of the
              partial surrender.

         o    A partial surrender may terminate the Death
              Benefit Guarantee to age 85 (DBG-85) or the Death
              Benefit Guarantee to age 100 (DBG-100).  The
              surrender amount is deducted from total premiums
              paid, which may reduce the total below the level
              required to keep the DBG-85 or the DBG-100 in
              effect.

         o    If Option 1 is in effect, the specified amount
              will be reduced by the amount of the partial
              surrender and fee.

              Because the specified amount is reduced, partial
              surrenders may affect the cost of insurance.  IDS
              Life will not allow a partial surrender if it<PAGE>
PAGE 15
              would reduce the specified amount below the
              required minimum.

         o    If Option 2 is in effect, a partial surrender
              does not affect the specified amount.
    
         Transfers between the fixed account and subaccounts

         The owner may transfer policy values from one
         subaccount to another or between subaccounts and the
         fixed account.  For most transfers, if IDS Life
         receives the request before the close of business, it
         will process it that day.  Requests received after the
         close of business will be processed the next business
         day.  There is no charge for transfers.  Before
         transferring policy value, the owner should consider
         the risks involved in switching investments.

         IDS Life may suspend or modify the transfer privilege
         at any time.  Transfers involving the fixed account are
         subject to the restrictions below.

         Fixed account transfer policies

         o    Transfers from the fixed account must be made
              during a 30-day period starting on a policy
              anniversary, except for automated transfers,
              which can be set up for monthly, quarterly or
              semiannual transfer periods.

         o    If IDS Life receives the request to transfer
              funds from the fixed account within 30 days
              before the policy anniversary, the transfer will
              become effective on the anniversary.

         o    If IDS Life receives the request on or within 30
              days after the policy anniversary, the transfer
              will be effective on the day we receive it.

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

         o    If the owner has made a transfer from the fixed
              account to one or more subaccounts, they may not
              make a transfer from any subaccount back to the
              fixed account until the next policy anniversary. 
              IDS Life will waive this limitation once during
              the first two policy years if the owner exercises
              the policy's right to exchange provision.

         Minimum transfer amounts

         From a subaccount to another subaccount or the fixed
         account:  For mail and phone transfers, $250 or the
         entire subaccount balance, whichever is less.  For
         automated transfers, $50.
<PAGE>
PAGE 16
         From the fixed account to a subaccount:  $250 or the
         entire fixed account balance minus any outstanding
         indebtedness, whichever is less.  For automated
         transfers, $50.

         Maximum transfer amounts

         From a subaccount to another subaccount or the fixed
         account:  None.

         From the fixed account to a subaccount:  Entire fixed
         account balance minus any outstanding indebtedness.

         Maximum number of transfers per year

         IDS Life reserves the right to limit mail and telephone
         transfers to five per policy year.  Twelve automated
         transfers per policy year are allowed.

         Two ways to request a transfer, loan or surrender

         The owner should provide their name, policy number,
         Social Security Number or Taxpayer Identification
         Number then they request a transfer, loan or partial
         surrender.

         1  By letter

         Regular mail:

         IDS Life Insurance Company
         P.O. Box 499
         Minneapolis, MN  55440-0499

         Express mail:

         IDS Life Insurance Company
         733 Marquette Ave.
         Minneapolis, MN  55402

         2  By phone

         Call between 7 a.m. and 6 p.m. Central Time:
         1-800-437-0602 (toll free) or
         (612) 671-4738 (Minneapolis/St. Paul area)

         TTY service for the hearing impaired:
         1-800-285-8846 (toll free)

         o    IDS Life answers phone requests promptly, but the
              owner may experience delays when call volume is
              unusually high.  If the owner is unable to get
              through, use mail procedure as an alternative.

         o    IDS Life will honor any telephone transfer, loan
              or partial surrender requests believed to be
              authentic and will use reasonable procedures to<PAGE>
PAGE 17
              confirm that they are.  These include asking
              identifying questions and tape recording calls. 
              As long as the procedures are followed, neither
              IDS Life nor its affiliates will be liable for
              any loss resulting from fraudulent requests.

         o    Telephone transfers, loans and partial surrenders
              are automatically available.  The owner may
              request that telephone transfers, loans and
              partial surrenders not be authorized from their
              account by writing IDS Life.

         Automated transfers

         In addition to written and phone requests, the owner
         can arrange to have policy value transferred from one
         account to another automatically.  Their financial
         advisor can help them set up an automated transfer.

         Automated transfer policies:

         o    Minimum automated transfer:  $50

         o    Frequency:  monthly, quarterly, semiannually or
              annually

         o    Only one automated transfer arrangement can be in
              effect at any time.  Policy values may be
              transferred to one or more subaccounts and the
              fixed account but can be transferred from only
              one account.

         o    The owner can start or stop this service by
              written request.  They must allow seven days for
              us to change any instructions that are currently
              in place.

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

         o    If the owner has made a transfer from the fixed
              account to one or more subaccounts, they may not
              make a transfer from the subaccount back to the
              fixed account until the next policy anniversary.

         o    If the owner's request is submitted with an
              application for a policy, it will not take effect
              until the policy is issued.

         o    If the value of the account from which policy
              value is being transferred is less than the $50
              minimum, the transfer arrangement will
              automatically be stopped.

         o    Automated transfers are subject to all other
              policy provisions and terms including provisions<PAGE>
PAGE 18
              relating to the transfer of money between the
              fixed account and the subaccounts.

         Automated dollar-cost averaging

         The owner can use automated transfers to take advantage
         of dollar-cost averaging -- investing a fixed amount at
         regular intervals.  For example, the owner might have a
         set amount transferred monthly from a relatively
         conservative subaccount to a more aggressive one, or to
         several others.

         This systematic approach can help the owner benefit
         from fluctuations in accumulation unit value, caused by
         fluctuations in the market value(s) of the underlying
         fund portfolio.  Since the owner invests the same
         amount each period, they automatically acquire more
         units when the market value falls, fewer units when it
         rises.  The potential effect is to lower the average
         cost per unit.

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

         Exchange right

         For two years after the policy is issued, the owner can
         exchange it for one that provides benefits that do not
         vary with the investment return of the subaccounts. 
         Because the policy itself offers a fixed return option,
         all the owner needs to do is transfer all of the policy
         value in the subaccounts to the fixed account.  IDS
         Life will automatically credit all future premium
         payments to the fixed account unless the owner requests
         a different allocation.

         Such transfer will not count against the five-
         transfers-per-year limit.  Also, any restrictions on
         transfers into the fixed account will be waived.

         There will be no effect on the policy's death benefit,
         specified amount, net amount at risk, risk
         classification(s) or issue age.  Only the method of
         funding the policy value will be affected.
       
    (e)  If the trust is the issuer of periodic payment plan
         certificates, the substance of the provisions of any
         indenture or agreement with respect to lapses or
         defaults by security holders in making principal
         payments, and with respect to reinstatement.
<PAGE>
PAGE 19
         Policy 1

         The Policy may lapse only if there is outstanding
         Indebtedness on the Policy.  The Policy will lapse if
         the total Indebtedness exceeds the Policy Value less
         Surrender Charges, of if the Surrender Value is
         insufficient to cover the monthly deduction.  If there
         is no outstanding Indebtedness, the Policy cannot
         lapse, even if the Policy Value equals $0.  If the
         Policy lapses, a grace period of 31 days shall be
         allowed for the policyholder to repay the lesser of the
         amount of the loan, the amount which leaves a
         sufficient Surrender Value to cover the monthly
         deduction, or the amount that the Indebtedness exceeds
         the Policy Value less Surrender Charges.  Notice of the
         necessity to pay such amount will be mailed to the
         Owner's last known address.  If repayment is not made
         prior to the expiration of the grace period, the policy
         will lapse without value.  If the Insured dies during
         the grace period, any Indebtedness or overdue monthly
         deduction will be deducted from the death benefit to
         determine the proceeds payable.

         Policy 2

         If, on a monthly date, the Cash Surrender Value is less
         than the monthly deduction for the next month, a grace
         period of 61 days will begin.  IDS Life will mail, to
         the Owner's last known address, a notice as to the
         premium needed, so that the estimated Cash Surrender
         Value will be sufficient to cover the next three
         monthly deductions.  If IDS Life receives payment of
         this amount before the end of the grace period, the
         amount will be used to cover all monthly deductions,
         and any other charges, then due.  Any balance will be
         added to the policy value and allocated in the same
         manner as other premium payments.  If the premium is
         not paid within the grace period and if the policy is
         not being continued under the Death Benefit Guarantee
         provision described below, all coverage under the
         policy will terminate without value at the end of the
         61-day grace period.

         If a claim by death during the grace period becomes
         payable under the policy, any overdue monthly
         deductions will be deducted from the proceeds.

         Until the insured's attained age 70, or five years from
         the policy date, whichever is later, the policy will
         not terminate even if the cash surrender value is
         insufficient to cover the monthly deduction on a
         monthly date if (a) equals or exceeds (b) where:

         (a)  is the sum of all premiums paid, minus any
              partial surrenders, and minus any indebtedness;
              and
<PAGE>
PAGE 20
         (b)  is the minimum monthly premium, as shown under
              Policy Date in the Policy, times the number of
              months since the Policy Date, including the
              current month.

         Minimum monthly premiums may be paid on other than a
         monthly basis as long as the sum of premiums paid is at
         least equal to the total required Minimum Monthly
         Premiums at all times.

         If on a monthly date, sufficient premiums have not been
         paid to maintain the Death Benefit Guarantee, an
         additional period of 61 days will be allowed for the
         payment of a premium sufficient to pay the required
         minimum monthly premiums.  Notice of such premium will
         be mailed to the Owner's last known address.  If the
         premium is not paid within this period, the death
         benefit guarantee provision will no longer be in effect
         and cannot be reinstated.

         The minimum monthly premium will change if the
         specified amount is increased or decreased or if riders
         are added, changed or terminated.  The new minimum
         monthly premium will apply from the date of the change.

         A death benefit guarantee charge is included in the
         monthly deduction in the first five policy years or
         until the insured's attained age 70, whichever is
         later.  The charge will not be taken if, as described
         above, the death benefit guarantee provision is no
         longer in effect.

         For any month that the monthly deduction is being paid
         for by a Waiver of Monthly Deduction Rider attached to
         the policy, the minimum monthly premium for that month
         will be zero.

         The policy may be reinstated within five years after
         the end of the grace period, unless it was surrendered
         for cash.  To do this, IDS Life will require all of the
         following:

              1.   a written request to reinstate the policy;

              2.   evidence of insurability of the insured
                   satisfactory to IDS Life;

              3.   payment of a premium that will keep the
                   policy in force for at least 3 months;

              4.   payment of the monthly deductions that were
                   not collected during the grace period;

              5.   payment or reinstatement of any
                   indebtedness.
<PAGE>
PAGE 21
         Surrender charges will also be reinstated.

         The effective date of a reinstated policy will be the
         monthly date on or next following the day IDS Life
         approves the application for reinstatement.

         The suicide and incontestability periods will apply
         from the effective date of reinstatement.  IDS Life
         will have two years from the effective date of
         reinstatement to contest the truth of statements or
         representations in the reinstatement application.

         Policy 3

         Keeping the policy in force

         This section includes a description of the policy
         provisions that determine if the policy will remain in
         force or lapse (terminate).  It is important that the
         owner understands them so the appropriate premium
         payments are made to ensure that insurance coverage
         meets their objectives.

         If the owner wishes to have a guarantee that the policy
         will remain in force until the youngest insured's
         attained insurance age 100 regardless of investment
         performance, they should pay at least the DBG-100
         premiums.

         If the owner wishes to pay a lower premium and is
         satisfied to have a guarantee that the policy will
         remain in force until the youngest insured's attained
         insurance age 85 (or 15 policy years, if later)
         regardless of investment performance, they should pay
         at least the DBG-85 premiums.
   
         If the owner wishes to pay yet a lower premium and is
         not concerned with a long-term guarantee that the
         policy will remain in force regardless of investment
         performance, they can pay premiums so that the cash
         surrender value on each monthly date is sufficient to
         pay the monthly deduction.  However, during the minimum
         initial premium period, they must pay at least the
         minimum initial premium until the policy value is
         greater than the surrender charge and the cash
         surrender value is sufficient to pay the monthly
         deduction.  At that time they may be able to reduce
         their premiums as long as the cash surrender value
         continues to be sufficient to pay the monthly
         deduction.
    
         Death benefit guarantee to age 85

         The DBG-85 provides that the owner's policy will remain
         in force until the youngest insured reaches attained
         insurance age 85 (or 15 policy years, if later) even if
         the cash surrender value is insufficient to pay the<PAGE>
PAGE 22
         monthly deduction.  The DBG-85 will remain in effect,
         as long as:

              the sum of premiums paid - partial surrenders -
              outstanding indebtedness

              equals or exceeds

              the DBG-85 premiums due since the policy date.

         The DBG-85 premium is shown in the policy.
   
         If, on a monthly date, the owner has not paid enough
         premiums to keep the DBG-85 in effect, an additional
         period of 61 days will be allowed for the owner to pay
         a premium sufficient to bring their total up to the
         required minimum.  If they do not pay this amount
         within 61 days, the DBG-85 will terminate.  Their
         policy will also lapse (terminate) if the cash
         surrender value is less than the amount needed to pay
         the monthly deduction and the minimum initial premium
         period is not in effect.  Although the policy can be
         reinstated as explained below, the DBG-85 cannot be
         reinstated.
    
         Death benefit guarantee to age 100

         The DBG-100 provides that the owner's policy will
         remain in force until the youngest insured's attained
         insurance age 100 even if the cash surrender value is
         insufficient to pay the monthly deduction.  The DBG-100
         will remain in effect, as long as:

              the sum of premiums paid - partial surrenders -
              outstanding indebtedness

              equals or exceeds

              the DBG-100 premiums due since the policy date.

         The DBG-100 premium is shown in the policy.
   
         If, on a monthly date, they have not paid enough
         premiums to keep the DBG-100 in effect, an additional
         period of 61 days will be allowed for the owner to pay
         a premium sufficient to bring their total up to the
         required minimum.  If they do not pay this amount
         within 61 days, the DBG-100 will terminate.  If they
         have paid sufficient premium, the DBG-85 will be in
         effect.  If the DBG-85 and DBG-100 are not in effect,
         the policy will lapse (terminate) if the cash surrender
         value is less than the amount needed to pay the monthly
         deduction and the minimum initial premium period is not
         in effect.  Although the policy can be reinstated as
         explained below, the DBG-100 cannot be reinstated.
    <PAGE>
PAGE 23
   
         Minimum initial premium period

         To allow the owner the opportunity to increase their
         policy value gradually so that the cash surrender value
         is sufficient to pay the monthly deduction, the owner
         may choose to pay only the minimum initial premium
         during the minimum initial premium period as long as
         the policy value minus indebtedness equals or exceeds
         the monthly deduction.  The policy will not enter the
         grace period during the minimum initial premium period
         as shown under Policy Date, if:

         1.   on a monthly date, the policy value minus
         indebtedness equals or exceeds the monthly deduction
         for the policy month following such monthly date; and

         2.   the sum of all premiums paid, minus any partial
         surrenders, and minus any indebtedness equals or
         exceeds the minimum initial premium, as shown under
         Policy Date, times the number of months since the
         Policy Date, including the current month.

         The minimum initial period is

              4 years if the youngest insured's insurance age
              is 20-29
              3 years if the youngest insured's insurance age
              is 30-39
              2 years if the youngest insured's insurance age
              is 40-49
              1 year if the youngest insured's insurance age is
              50 and over

         Grace period

         If the cash surrender value of the policy becomes less
         than that needed to pay the monthly deduction and
         neither of the death benefit guarantees nor the minimum
         initial premium period is in effect, the owner will
         have 61 days to pay the required premium amount.  If
         the required premium is not paid, the policy will
         lapse.

         IDS Life will mail a notice to their last known
         address, requesting payment of the premium needed so
         that the next three monthly deductions can be made.  If
         IDS Life receives this premium before the end of the
         61-day grace period, IDS Life will use the payment to
         pay all monthly deductions and any other charges then
         due.  Any balance will be added to the policy value and
         allocated in the same manner as other premium payments.

         If a policy lapses with outstanding indebtedness, any
         excess of the outstanding indebtedness over the premium
         paid generally will be taxable to the owner.  If the
         last surviving insured dies during the grace period,<PAGE>
PAGE 24
         any overdue monthly deductions will be deducted from
         the death benefit.
    
         Reinstatement

         The owner's policy may be reinstated within five year
         after it lapses, unless they surrendered it for cash. 
         To reinstate, IDS Life will require:

         o    a written request;

         o    evidence satisfactory to IDS Life that both
              insureds remain insurable or evidence for the
              last surviving insured and due proof that the
              first death occurred before the date of lapse;
   
         o    payment of a premium that will keep the policy in
              force for at least three months (one month in
              Virginia);
    
         o    payment of the monthly deductions that were not
              collected during the grace period; and

         o    payment or reinstatement of any indebtedness.
   
         The effective date of a reinstated policy will be the
         monthly date on or next following the day IDS Life
         accepts the owner's application for reinstatement.  The
         suicide period will apply from the effective date of
         reinstatement (except in Georgia, Oklahoma, Tennessee,
         Utah and Virginia).  Surrender charges will also be
         reinstated.
       
         IDS Life will have two years from the effective date of
         reinstatement (except in Virginia) to contest the truth
         of statements or representations in the reinstatement
         application.
    
    (f)  The substance of any provisions of any indenture or
         agreement with respect to voting rights, together with
         the names of any persons other than security holders
         given the right to exercise voting rights pertaining to
         the trust's securities or the underlying securities and
         the relationship of such persons to the trust.
   
         The Variable Account is comprised of various
         subaccounts.  Subaccounts P,Q,R,S, and T, as well as
         Subaccounts 1995 and 2004 fund the Single Premium
         Variable Life policies issued by IDS Life.  Subaccounts
         U,V,W,X,Y, and IL, as well as Subaccounts 1995V and
         2004V fund the Flexible Premium Variable Life policies
         issued by IDS Life.  Subaccounts U,V,W,X,Y and IL also
         fund the Flexible Premium Survivorship Variable Life
         Insurance Policy issued by IDS Life.  Some Subaccounts
         invest exclusively in the Portfolios of IDS Life Series
         Fund (the Fund), while others invest in units of the
         Smith Barney Inc. Stripped (Zero Coupon) U.S. Treasury<PAGE>
PAGE 25
         Securities Fund, Series A ("the Trust" or "the
         Trusts").  Subaccount P and U invest exclusively in the
         shares of the Equity Portfolio; Subaccounts Q and V
         invest exclusively in the shares of the Income
         Portfolio; Subaccounts R and W invest exclusively in
         the shares of Money Market Portfolio; Subaccounts S and
         X invest exclusively in the shares of the Managed
         Portfolio; Subaccounts T and Y invest exclusively in
         the shares of the Government Securities Portfolio; and
         Subaccount IL invests exclusively in the shares of the
         International Equity Portfolio.  All of the above six
         portfolios make up IDS Life Series Fund, Inc., a series
         mutual fund.  Subaccounts 1995, 2004, 1995V and 2004V
         invest in units of the designated unit investment
         trust, with maturity dates of 1995 and 2004
         respectively.
    
         All shares issued by the Fund are the same class (kind)
         capital stock.  They have a par value of $.001 a share. 
         They are fully paid and nonassessable and can be
         redeemed or transferred.  All shares have equal voting
         rights.  They can be issued as full shares or
         fractions.  A fraction of a share has the same kind of
         rights and privileges as a full share.  The Fund
         currently has six portfolios, each issuing its own
         series of common stock.  The shares of each portfolio
         represent an interest only in that portfolio's assets
         (and profits or losses) and in the event of
         liquidation, each share of a portfolio would have the
         same rights to dividends and assets as every other
         share of that portfolio.

         Each share of a portfolio has one vote.  On some
         issues, such as the election of directors, all shares
         of the Fund vote together as one series.  All shares
         have cumulative voting when voting on the election of
         directors.  With cumulative voting, each shareholder is
         entitled to a number of votes equal to the number of
         shares which that shareholder holds multiplied by the
         number of directors to be elected, and has the right to
         divide votes among candidates in any way.  On an issue
         affecting a particular portfolio, its shares vote as a
         separate series.  An example of such an issue would be
         a fundamental investment restriction pertaining to only
         one portfolio.  In voting on the Investment Management
         and Services Agreement, approval of the Agreement by
         the shareholders of a particular portfolio would make
         the Agreement effective as to that portfolio, whether
         or not it had been approved by the shareholders of the
         other portfolios.
   
         As previously stated, all of the assets held in the
         subaccounts will be invested in shares of the
         corresponding portfolio or in units of the Trust.  With
         regard to the Fund IDS Life is the Owner of those Fund
         shares as such has the right to vote to elect the Board
         of Directors of the Fund, to vote upon certain matters<PAGE>
PAGE 26
         that are required by the 1940 Act to be approved or
         ratified by the shareholders, and to vote upon any
         other matter that may be voted upon at a shareholders'
         meeting.  However, IDS Life will vote the shares of
         each Fund portfolio at regular and special meetings of
         the shareholders of the Fund in accordance with
         instructions received from the owners of the Policies. 
         Fund shares held in each subaccount for which no timely
         instructions from Owners are received, and Fund shares
         that are not otherwise attributable to Owners, will be
         voted by IDS Life in the same proportion as those
         shares in that subaccount for which instructions are
         received.  The number of Fund shares in each subaccount
         for which instructions may be given by an Owner is
         determined by applying the Owner's percentage interest
         in the subaccount to the total number of votes
         attributable to the subaccount.  The number will be
         determined as of a date chosen by IDS Life, but not
         more than 60 days before the meeting of the Fund. 
         Fractional votes are counted.  Owners will receive
         notice of each meeting of the shareholders together
         with any proxy solicitation materials, and a statement
         of the number of votes as to which they are entitled to
         give directions at the meeting.
    
         IDS Life may, if required by state insurance officials,
         disregard voting instructions if such instructions
         would require shares to be voted so as to cause a
         change in the goals of one or more of the Funds'
         portfolios, or to approve or disapprove an investment
         advisory contract for the Fund. In addition, IDS Life
         itself may disregard voting instructions that would
         require changes in the investment policy or investment
         adviser of one or more of the Fund's portfolios,
         provided that IDS Life reasonably disapproves such
         changes in accordance with applicable federal
         regulations.  If IDS Life does disregard voting
         instructions, it will advise Owners of that action and
         its reasons for such action in the next report to
         Owners.

         Generally, ownership of units of a unit investment
         trust does not involve the exercise of voting rights. 
         However, with regard to the Trusts, unitholders may
         vote for removal of the trustee or for the amendment or
         the termination of the Trust indenture.  In the event
         of such vote, IDS Life, as the Owner of such units,
         would solicit voting instructions from Owners under the
         same procedures set forth above regarding the holders
         of Fund shares.

    (g)  Whether security holders must be given notice of any
         change in:

         (1)  the composition of the assets of the trust.  
<PAGE>
PAGE 27
              If shares of any Fund portfolio or Trust units
              should not be available for purchase by the
              appropriate subaccount or if, in the judgment of
              IDS Life's management, further investment in such
              shares is no longer appropriate in view of the
              purposes of the subaccount, shares of another
              registered, open-end management investment
              company or unit investment trust may be
              substituted for portfolio shares or Trust units
              held in the subaccount.  If deemed by IDS Life to
              be in the best interest of persons having voting
              rights under the Policy, the Variable Account may
              be operated as a management company under the
              Investment Company Act of 1940 or it may be
              deregistered under such Act in the event such
              registration is no longer required.  In the event
              of any such substitution or change, IDS Life may,
              without the consent or approval of the Owners,
              amend the Policy and take whatever action is
              necessary and appropriate.  However, no such
              substitution or change will be made without any
              necessary approval of the SEC.  IDS Life will
              notify Owners within five days of any
              substitution or change.

         (2)  the terms and conditions of the securities issued
              by the trust.

         No change in the terms and conditions of an issued and
         outstanding Policy can be made without the consent of
         the Owner, other than as set forth in paragraph (1)
         above.

         (3)  the provisions of any indenture or agreement of
              the trust.

              Not applicable.

         (4)  the identity of the depositor, trustee or
              custodian.  

              There is no provision requiring notice to, or
              consent of, Owners with respect to any change in
              the identity of the Variable Account's depositor. 
              However, IDS Life's obligations under the Policy
              cannot be transferred to any other entity without
              the consent of the Owner.

    (h)  Whether the consent of security holder for action to be
         taken concerning any change in:

         (1)  the composition of the assets of the trust.  

              Consent of Owners is not required when changing
              the underlying securities of any of the
              Subaccounts.  However, to change these
              securities, approval of the Securities and<PAGE>
PAGE 28
              Exchange Commission is required in compliance
              with Section 26(b) of the Investment Company Act
              of 1940.

         (2)  the terms and conditions of the securities issued
              by the trust.
 
         No change in the terms and conditions of the Policy may
         be made without the consent of the Owner, except as
         provided in paragraph (1) above.

         (3)  the provisions of any indenture or agreement of
              the trust.

              Not applicable.

         (4)  the identity of the depositor, trustee or
              custodian.

         The answer to Item 10(g)(4) is incorporated by
         reference.

    (i)  Any other principal feature of the securities issued by
         the trust or any other principal right, privilege or
         obligation not covered by subdivisions (a) to (g) or by
         any other item in this form.

         Policy 1

         The minimum single premium must be at least $5000.  The
         maximum single premium is $500,000.  The Policy
         provides life insurance coverage on the lives of the
         named insureds. The Policy allows the Owner to borrow
         from its Policy Value, using that value as collateral
         for the loan.

         Policy 2

         The Owner has flexibility concerning the amount and
         frequency of premium payments.  At the time of
         application, the Owner will determine a Scheduled
         Premium.  The Scheduled Premium will be a level amount
         at a fixed interval of time. However, the Owner need
         not adhere to the Scheduled Premium. Instead, the Owner
         may, subject to certain restrictions, make premium
         payments in any amount and at any frequency.

         Premium payments may be increased or decreased at any
         time. The minimum payment which IDS Life will accept is
         $25.  There is no maximum, but IDS Life reserves the
         right to limit any payment.

         The failure to pay a scheduled premium will not itself
         cause the Policy to lapse.  However, the payment of
         scheduled premiums or unscheduled premiums in any
         amount or frequency will not guarantee that the Policy
         will remain in force.  Subject to the limitations<PAGE>
PAGE 29
         contained in the Policy, payment the Minimum Monthly
         Premium will keep the coverage in force until the later
         of the insured's Age 70 Anniversary or five years from
         the policy date.

         The Policy contains two death benefit options.  Under
         Death Benefit Option 1, the death benefit is the
         greater of the Specified Amount or a percentage of
         policy value.  Under Death Benefit Option 2, the death
         benefit is the greater of the Specified Amount plus the
         policy value, or a percentage of policy value.

         Before issuing any policy, IDS Life requires evidence
         of insurability satisfactory to it.  IDS Life will
         generally not issue a policy to persons over the age of
         75.  It may, however, at its sole discretion, issue a
         policy to an applicant above age 75.  The Initial
         Minimum Specified Amount is $50,000, but this is
         reduced to $40,000 in Policy Years 3 through 10, and
         25,000 thereafter.  The minimum specified amount for
         policies purchased on or after May 1, 1991 with an
         initial specified amount of $350,000 or more is
         $350,000 in the first policy year, $325,000 in years
         two to five, $300,000 in years six to 10 and $275,000
         thereafter.

         The Owner may borrow up to 85 percent of the Policy
         Value less Surrender Charges at a 6.1 percent interest
         rate, payable in advance.  For policies purchased on or
         after May 1, 1993 (October 1, 1993 for New Jersey), IDS
         Life expects to reduce the loan interest rate after a
         policy's 10th anniversary to 4.3%.  The borrowed
         amounts are placed in IDS Life's fixed account.  If the
         Owner does not specify whether to borrow the money from
         the Fixed Account and/or any specific subaccount, or if
         the Fixed Account or the designated subaccounts do not
         have sufficient values, the loan will be taken pro rata
         from the Fixed Account and each subaccount.  The Fixed
         Account value attributable to indebtedness will earn
         4.50 percent annual interest.  The minimum loan which
         can be requested $500.

         Policy 3

         Premiums

         Payment of premiums:

         In applying for the policy, the owner must decide how
         much they intend to pay and how often they will make
         payments.  During the early policy years until the
         policy value is sufficient to cover the surrender
         charge, IDS Life requires that the owner pay the
         premiums sufficient to keep the DBG-85 in effect.The
         owner may schedule payments annually, semiannually, or
         quarterly.  (Payment at any other interval must be<PAGE>
PAGE 30
         approved by IDS Life.)  This premium schedule is shown
         in the policy.
  
         The scheduled premium serves only as an indication of
         the owner's intent as to the frequency and amount of
         future premium payments.  The owner may skip scheduled
         premium payments at any time if their cash surrender
         value is sufficient to pay the monthly deduction, or if
         they have paid sufficient premium to keep the DBG-85 or
         the DBG-100 in effect.

         The owner may also change the amount and frequency of
         scheduled premium payments by written request.  IDS
         Life reserves the right to limit the amount of such
         changes.  Any change in the premium amount is subject
         to applicable tax laws and regulations. 

         Although the owner has flexibility in paying premiums,
         the amount and frequency of their payments will affect
         the policy value, cash surrender value and length of
         time their policy will remain in force, as well as
         affect whether the DBG-85 or DBG-100 remain in effect.

         Premium limitations:

         The owner may make unscheduled premium payments at any
         time and in an amount of at least $50.  IDS Life
         reserves the right to limit the number and amount of
         unscheduled premium payments.

         No premium payments, scheduled or unscheduled, are
         allowed on or after the youngest insured's attained
         insurance age 100.

         Also, in order to receive favorable tax treatment under
         the Code, premiums paid during the life of the policy
         must not exceed certain limitations.  To comply with
         the Code, IDS Life can either refuse excess premiums as
         they are paid, or refund excess premiums with interest
         no later than 60 days after the end of the policy year
         in which they were paid.

         Allocation of premiums:
   
         Until the policy date, IDS Life holds all premiums in
         the fixed account, and IDS Life credits interest on the
         net premiums (gross premiums minus premium expense
         charge) at the current fixed account rate.  As of the
         policy date, IDS Life will allocate the net premiums
         plus accrued interest to the account(s) the owner has
         selected in their application.  At that time,  IDS Life
         will begin to assess the various loads, fees, charges
         and expenses.
    
         Any amount allocated to a subaccount is converted into
         accumulation units of that subaccount.  Similarly, when
         transferring value between subaccounts, accumulation<PAGE>
PAGE 31
         units in one subaccount are converted into a cash
         value, which is then converted into accumulation units
         of the second subaccount. 

         Insurability: Before issuing the policy, IDS Life
         requires satisfactory evidence of the insurability of
         the persons whose lives the owner proposes to insure. 
         IDS Life's underwriting department will review the
         owner's application and any medical information or
         other data required to determine whether the proposed
         individuals are insurable under IDS Life's underwriting
         rules.  The owner's application may be declined if a
         person fails to meet the underwriting requirements  and
         any premiums that were paid will be returned.  

         Age limit: IDS Life generally will not issue a policy
         to persons over the insurance age of 85.  It may,
         however, do so at its sole discretion. 
   
         Proceeds payable upon death
    
         IDS Life will pay a benefit to the beneficiary of the
         policy when the last surviving insured dies.  If that
         death is prior to the youngest insured's attained
         insurance age 100, the amount payable is based on the
         specified amount and death benefit option the owner has
         selected, as described below, less any indebtedness.

         If the last surviving insured's death is on or after
         the youngest insured's attained insurance age 100, the
         amount payable is the cash surrender value.

         Option 1 (level amount): Under this option, the
         policy's value is part of the specified amount.  The
         Option 1 death benefit is the greater of:

              o the specified amount on the date of the last    
                 surviving insured's death; or

              o the applicable percentage of the policy value on
                 the date of the last surviving insured's death,
                 if that death occurs on a valuation date, or on
                 the next valuation date following the date of
                 death.  

         Option 2 (variable amount): Under this option, the
         policy value is added to the specified amount.  The
         Option 2 death benefit is the greater of:

               o the policy value plus the specified amount; or
               o the applicable percentage of policy value on
                 the date of the last surviving insured's death,
                 if that death occurs on a valuation date, or
                 on the next valuation date following the date of
                 death.
<PAGE>
PAGE 32
Information Concerning the Securities Underlying the Trust's
Securities

11. Describe briefly the kind or type of securities comprising
    the unit of specified securities in which the security
    holders have an interest.

    The securities to be held in the Subaccounts will be shares
    of the Fund or units of the Trust described in Item 12.  This
    fund is a registered, open-end diversified management
    investment company.  The Trust is a registered unit
    investment trust (UIT).

12. If the trust is the issuer of periodic payment plan
    certificates, and if any underlying securities were issued by
    another investment company, furnish the following information
    for each such company:
   
    (a)  Name of Company.

         IDS Life Series Fund, Inc.
         The Smith Barney Inc. Stripped ("Zero Coupon") U.S.
         Treasury Securities Fund, Series A ("Zero Coupon Trust"
         - a unit investment Trust).

    (b)  Name and principal address of depositor.

         Investment manager of IDS Life Series Fund, Inc.
         IDS Life Insurance Company
         IDS Tower 10
         Minneapolis, MN  55440

    (c)  Name and principal business address of trustee or
         custodian.

         For IDS Life Series Fund, Inc.:

         American Express Trust Company
         P.O. Box 534
         Minneapolis, Minnesota  55440-0534

         acts as custodian for the Fund.

         Sponsor of the Zero Coupon Trust:

         Smith Barney Inc.
         Two World Trade Center
         New York, NY  10048

    (d)  Name and principal business address of principal
         underwriter.

         Not Applicable.     
<PAGE>
PAGE 33
    (e)  The period during which the securities of such Company
         have been the underlying securities.

         IDS Life Series Fund, Inc. commenced operations on
         January 20, 1986.  The International Equity Portfolio
         commenced operations on October 28, 1994.
    
Information Concerning Loads, Fees, Charges and Expenses

13. (a)  Furnish the following information with respect to each
         load, fee, expense or charge to which (1) principal
         payments, (2) underlying securities, (3) distributions,
         (4) cumulated or reinvested distributions or income,
         and (5) redeemed or liquidated assets or the trust's
         securities are subject:

              (A)  the nature of such load, fee, expense or
                   charge;
              (B)  the amount thereof; 
              (C)  the name of the person to whom such amounts
                   are paid and his relationship to the trust;
              (D)  the nature of the services performed by
                   such person in consideration for such load,
                   fee, expense or charge.

         (1)   Principal Payments.  (Gross Premium)
<TABLE><CAPTION>
         Policy 1
 
                 Nature of                                   Person to whom
                 Charge        Amount                        Paid/Relationship   Services
                 <S>           <C>                            <C> 
                 Monthly Cost  Tabular charge per $1,000 at   IDS Life           Insurance
                 of insurance  risk, varying by age, sex                         Protection
                 charges       and insurance rating of the
                               insured

                 Policy Issue   $150 at time of issue         IDS Life           Issue and
                 and Admin-                                                      Administrative
                 istrative                                                       Expenses
                 Expense

                 Surrender     Percent of Amount              IDS Life           Sales Expenses
                 Charge        Surrendered varying by
                               duration and guaranteed
                               not to exceed 9% of
                               Premium paid

                 Premium Tax   2.5% of Premium                IDS Life           State
                 Charge                                                          Premium
                                                                                 Taxes

               Policy 2

                 Nature of                                    Person to whom
                 Charge        Amount                         Paid/Relationship  Services

                 Sales         2.5% of Gross Premiums         IDS Life           Sales
                 Charge                                                          Expenses

                 Premium       2.5% of Gross Premiums         IDS Life           State
                 Tax Charge                                                      Premium
                                                                                 Taxes
<PAGE>
PAGE 34
                 Policy        Currently $5 per policy        IDS Life           Adminis-
                 Fee           month, never to exceed                            trative
                               $7.50 per policy month.                           Expenses
                               Waived for policies
                               purchased on or after
                               May 1, 1991 with an
                               initial specified amount
                               of $350,000 or more.

                 Cost of       Tabular charge per $1000       IDS Life           Insurance
                 Insurance     net amount at risk each                           Protection
                 Charge        policy month, determined by
                               age, sex and insurance
                               rating of the insured

                 Cost of       Tabular charge each policy     IDS Life           Optional
                 Policy        month determined by nature                        Insurance
                 Riders        and amount of riders
                               attached to policy

                 Death         $0.01 per $1000 of             IDS Life           Death
                 Benefit       Specified Amount and Other                        Benefit
                 Guarantee     Insured Rider Coverage each                       Guarantee
                 Charge        policy month that the Death                       Risk
                               Benefit Guarantee is in
                               effect

                 Contingent    $4 per $1000 Initial           IDS Life           Issue
                 Deferred      Specified Amount of policy                        and
                 Issue and     is surrendered within 5                           Under-
                 Adminis-      years of policy issue,                            writing
                 trative       decreasing monthly                                Expenses
                 Expense       thereafter at a rate of 20%                       at Issue
                 Charge        per year
                 (Issue)

                 Contingent    $4 per $1000 increase in       IDS Life           Issue
                 Deferred      Specified Amount if policy                        and
                 Issue and     is surrendered within 5                           Under-
                 Adminis-      policy years of increase,                         writing
                 trative       decreasing monthly                                Expenses
                 Expense       thereafter at a rate of 20%                       at 
                 Charge        per year                                          Increase
                 (Increase)

                 Contingent    27.5% of Gross Premiums up     IDS Life           Sales
                 Deferred      to amount shown in policy                         Expenses
                 Sales         (conservative estimate of                         at Issue
                 Charge        one Guideline Annual
                 (Issue)       Premium) plus 6.5% of all
                               other Gross Premiums except
                               those attributable to an
                               Increase or, if less
                               Tabular amount per $1000
                               Initial Specified Amount -
                               determined by age, sex and
                               insurance rating of insured
                               - if policy is surrendered
                               within 5 policy years of
                               issue, decreasing monthly
                               thereafter at a rate of 20%
                               per year

                 Contingent    6.5% of Premiums attrib-       IDS Life           Sales
                 Deferred      utable to the Increase                            Expenses  
                 Sales         or, if less Tabular                               at
                 Charge        amount per $100                                   Increase
                 (Increase)    increased in Specified
                               Amount - determined by age,
                               sex and insurance rating of
                               insured - if policy is
                               surrendered within 5 policy
                               years of Increase,
                               decreasing monthly
                               thereafter at a rate of 20%
                               per year<PAGE>
PAGE 35
                 Partial       $25 or, if less, 2% of          IDS Life          Trans-
                 Surrender     Policy Value surrendered                          action
                 Fee                                                             Costs

               Policy 3

                 Nature of                                    Person to whom
                 Charge        Amount                         Paid/Relationship  Services
   
                 Sales         7.25% of all premiums paid.     IDS Life          Sales
                 Charge                                                          Expenses
    
                 Premium       2.5% of premium payment.        IDS Life          State
                 Tax Charge                                                      Premium
                                                                                 Taxes 
                 Federal      1.25% of each premium            IDS Life          Federal 
                 Tax Charge   payment.                                           taxes
   
                 Policy       Currently $30 per policy         IDS Life          Adminis-
                 Fee          month, never to exceed                             trative
                              $30 per policy month.                              Expenses
    
                 Cost of      The monthly cost of insurance    IDS Life          Insurance
                 Insurance    times the total of the death                       Protection
                              benefit minus the policy value
                              plus any other flat extra 
                              insurance charges.

                 Cost of      Determined by nature and         IDS Life          Optional
                 Policy       amount of riders attached                          Insurance
                 Riders       to policy.
   
                 Contingent   $4 per $1000 of the initial      IDS Life          Issue 
                 Deferred     specified amount of the                            and
                 Issue and    policy, if it is surrendered                       Under-
                 Adminis-     during the first policy                            writing
                 trative      years, and then decreasing                         Expenses
                 Expense      monthly until it is zero at                        at Issue
                 Charge       the end of 15 policy years.                          
                 (Surrender
                 Charge)
    
 
                 Partial      $25 (or 2% of the amount         IDS Life          Trans-
                 Surrender    surrendered, if less).                             action
                 Fee                                                             Costs

                (2)     Underlying Security.
   
                Investment    The Money Market                 IDS Life          Investment
                Management    Portfolio of IDS Life                              management
                Fee           Series Fund, Inc.                                  and services
                              pays a fee on an                                   described in
                              annual basis equal to                              Agreement
                              0.50% of its daily
                              aggregate average
                              net assets.
       
                              The Equity, Income
                              Managed and
                              Government Securities
                              Portfolios of IDS Life
                              Series Fund, Inc. each
                              pay a fee on an annual
                              basis equal to 0.70% of
                              their aggregate average
                              daily net assets.
                                    
                              The International Equity
                              Portfolio of IDS Life
                              Series Fund, Inc. pays a
                              fee on an annual basis 
                              equal to 0.95% of its
                              aggregate average daily
                              net assets.
    <PAGE>
PAGE 36
                Non-Advisory  IDS Life Series Fund,            IDS Life          Non-Advisory
                Expense       Inc. will reimburse                                Expenses
                Charges       IDS Life for non-                                  described in
                              advisory expenses.                                 Agreement
</TABLE>
         (3)  Distributions.

              Not applicable.  See paragraph (4) below.

         (4)  Cumulated or reinvested distributions or income.
   
              All investment income and other distributions are
              reinvested in Fund shares at net asset value.
    
         (5)  Redeemed or liquidated assets.  

              There are no charges for redeemed or liquidated
              assets of the Trust's securities.

    (b)  For each installment payment type of periodic payment
         plan certificate of the trust, furnish the following
         information with respect to sales load and other
         deductions from principal payments.

         Policy 1
   
         See Item 13(a)(1).
    
         Policy 2
   
         See Item 13(a)(1).
    
         Policy 3
   
         See Item 13(a)(1).
       
    (c)  State the amount of total deductions as a percentage of
         the net amount invested for each type of security
         issued by the trust.  State each different sales charge
         available as a percentage of the public offering price
         and as a percentage of the net amount invested.  List
         any special purchase plans or methods established by
         rule or exemptive order that reflect scheduled
         variations in, or elimination of, the sales load and
         identify each class of individuals or transactions to
         which such plans apply.
    
         Policy 1

         (1) 0%  However, this does not take into account the
         Surrender Charge described in Item 13(a)(1).  The
         surrender charge will not exceed 9% of the Premium.

         (2) 0%  However, this does not take into account the
         Surrender Charge or the other deductions described in
         Item 13(a)(1).
<PAGE>
PAGE 37
         Policy 2
   
         (1)  2.5%  However, this does not take into account
              the Contingent Deferred Sales Charge described in
              Item 13(a)(1).  The Contingent Deferred Sales
              Charge will not exceed 27.5% of payments up to
              one Guideline Annual Premium plus 6.5% of
              payments in excess of one Guideline Annual
              Premium; and 6.5% of any other amounts
              attributable as premiums after an Increase in
              Specified Amount.

         (2)  5.0%  However, this does not take into account
              the Contingent Deferred Sales Charge or
              Contingent Deferred Issue and Administrative
              Expense Charge or any of the other deductions
              from Policy Value described in Item 13(a)(1).
    
         Policy 3
   
         (1),(2)   Sales charge:  7.25% of all premiums paid. 
                   However, this does not take into account
                   the Contingent Deferred Issue and
                   Administrative Expense Charge or any of the
                   other deductions from Policy Value
                   described in Item 13(a)(1).
    
         Premium tax charge:  2.5% of each premium payment.

         Federal tax charge:  1.25% of each premium payment.
   
    (d)  Explain the reasons for any difference in the price at
         which securities are offered generally to the public,
         and the price at which securities are offered for any
         class of transactions to any class or group of
         individuals, including officers, directors, or
         employees of the depositor, trustee custodian or
         principal underwriter.
    
         Not Applicable.
   
    (e)  Furnish a brief description of any loads, fees,
         expenses or charges not covered in Item 13(a) which may
         be paid by security holders in connection with the
         trust or its securities.
    
         Policy 1

         IDS Life deducts a charge which on an annual basis is
         equal to 0.50% of the average assets of the Subaccounts
         as a mortality and expense risk charge.

         IDS Life deducts a charge which on an annual basis is
         equal to 0.15% of the average assets of the Subaccounts
         as a minimum death benefit guarantee risk charge.
<PAGE>
PAGE 38
         IDS Life reserves the right to charge the Subaccounts
         for any tax liability it may incur because of the
         operations of the Accounts regardless of whether or not
         tax is actually paid by IDS Life.

         Policy 2

         IDS Life deducts a Mortality and Expense Risk Charge,
         which is equal on an annual basis to 0.90% of the
         average assets of the Subaccounts.  This charge is
         needed to reimburse IDS Life for assuming certain
         mortality and expense risks under the Policy.

         IDS Life deducts a Transaction Charge, currently equal
         on an annual basis to 0.25% of the average assets of
         the Subaccounts investing in the Trusts.  IDS Life may
         increase this charge in the future but not to more than
         0.50%.  This is a cost-based charge needed to reimburse
         IDS Life for amounts paid to Smith Barney, Inc. on the
         sale of Trust units to the Variable Account.

         IDS Life reserves the right to charge the Subaccounts
         for any tax liability it may incur because of the
         operations of the Subaccounts, regardless of whether or
         not the tax is actually paid by IDS Life.

         Policy 3

         Mortality and expense risk charge

         This charge applies only to the subaccounts and not to
         the fixed account.  It is equal, on an annual basis, to
         0.9% of the daily net asset value of the subaccounts --
         a level guaranteed for the life of the policy. 
         Computed daily, the charge compensates IDS Life for:

             oMortality risk -- the risk that the cost of
              insurance charge will be insufficient to meet
              actual claims.

             oExpense risk -- the risk that the policy fee and
              the contingent deferred issue and administration
              expense charge may be insufficient to cover the
              cost of administering the policy.

         IDS Life reserves the right to make such a charge in
         the future if there is a change in the tax treatment of
         variable life insurance contracts or in  IDS Life's tax
         status as we currently understand it.
       
   
    (f)  State whether the depositor, principal underwriter,
         custodian or trustee, or any affiliated person of the
         foregoing may receive profits or other benefits not
         included in answer to Item 13(a) or 13(b) through the
         sale or purchase of the trust's securities or interests<PAGE>
PAGE 39
         in underlying securities, and described fully the
         nature and extent of such profits or benefits.
    
         Not as principal underwriter or depositor will IDS
         Life, nor any affiliated person of IDS Life, receive
         any profit or other benefit not included in the answer
         to Item 13(a) or 13(b) through the sale or purchase of
         the Policy or Fund shares, except that IDS Life will
         pay to American Express Financial Corporation a fee
         equal on an annual basis to 0.25% (0.50% for
         International Equity Portfolio) of the Fund's average
         net assets for investment advice relative to the Fund
         under an Investment Advisory Agreement between American
         Express Financial Corporation and IDS Life.

         As custodian of the underlying securities, American
         Express Trust Company will receive certain fees
         indirectly from the Fund.  The fees will be comparable
         to the fees received by custodians which hold the
         assets of other mutual funds.
   
    (g)  State the percentage that the aggregate annual charges
         and deductions for maintenance and other expenses of
         the trust, bear to the dividend and interest income
         from the trust property during the period covered by
         the financial statements filed herewith.
    
         Not applicable.
   
    (h)  For life insurance company separate accounts registered
         as unit investment trusts issuing variable life
         insurance contracts:

         If proceeds from explicit sales loads will not cover
         the expected costs of distributing the contracts,
         identify the source from which the shortfall, if any,
         will be paid.  If any shortfall is to be made up from
         assets from the Insurance Company's general account,
         disclose, if applicable, the extent to which any
         amounts paid by the Insurance Company may consist,
         among other things, of proceeds derived from mortality
         and expense risk charges deducted from the account.

         Mortality and expense risk charge

         This charge applies only to the subaccounts and not to
         the fixed account.  It is equal, on an annual basis, to
         0.9% of the daily net asset value of the subaccounts --
         a level guaranteed for the life of the policy. 
         Computed daily, the charge compensates IDS Life for:

             oMortality risk -- the risk that the cost of
              insurance charge will be insufficient to meet
              actual claims.
<PAGE>
PAGE 40
             oExpense risk -- the risk that the policy fee and
              the contingent deferred issue and administration
              expense charge may be insufficient to cover the
              cost of administering the policy.

         IDS Life may profit from the mortality and expense risk
         charge.  Any such profit would be available to IDS Life
         for any proper corporate purpose including, among
         others, payment of sales and distribution expenses,
         which we do not expect to be covered by the sales
         charges.  Any further deficit will have to be made up
         from IDS Life's general assets.
    
Information Concerning the Operations of the Trust

14. Describe the procedure with respect to applications (if any),
    and the issuance and authentication of the trust's
    securities, and state the substance of the provisions of any
    indenture or agreement pertaining thereto.

    A person desiring to purchase a Policy must complete an
    application on a form provided by IDS Life and submit it to
    the Home Office of IDS Life.  If the applicant meets the
    prescribed standards, a Policy will be issued.

15. Describe the procedure with respect to the receipt of
    payments from purchasers of the trust's securities and the
    handling of the proceeds thereof, and state the substance of
    the provisions of any indenture or agreement pertaining
    thereto.

    Policy 1

    The Owner determines in the application what portions, if
    any, of the premium are to be allocated to each of the
    Subaccounts.  Until the date that a policy is mailed from IDS
    Life's Home Office for delivery to the Owner, the premium
    received by IDS Life is held in IDS Life's general account. 
    When a Policy is mailed, the Policy Value will reflect the
    performance of Subaccount R, which invests in the Money
    Market Portfolio of IDS Life Series Fund, from the date the
    premium was received.  On the date that a Policy is mailed
    from IDS Life's Home Office for delivery to the Owner, the
    Policy Value will be allocated to one or more of the
    Subaccounts, in accordance with the allocation instructions
    received from the Owner in the application. Each of the
    Subaccounts invests exclusively in the shares of a different
    Portfolio of the Fund or units of the Trust.  The net
    investment results of each Subaccount vary with the
    investment experience of its underlying Fund Portfolio or
    valuation of Trust units.  For each of the Subaccounts, a
    unit price will be calculated daily by adding all investment 
    earnings of the Subaccount and deducting specified charges. 
    Thus, the value of each Policy varies with the investment
    performance of the underlying Fund Portfolio(s) or valuation
    of the Trust unit(s).<PAGE>
PAGE 41
    Policy 2

    The Owner determines in the application what portions, if
    any, of the premiums are to be allocated to each of the
    Subaccounts of the Variable Account, the Fixed Account or
    both.  Until the date that an application is approved by IDS
    Life's Home Office underwriting department, the premiums
    received by IDS Life are held in IDS Life's Fixed Account and
    interest at the current Fixed Account rate is credited on the
    net premiums (gross premium received minus the Premium
    Expense Charge).  As of the date that IDS Life's Home Office
    underwriting department approves the application, the net
    premiums plus interest accrued thereon will be allocated to
    the Fixed Account and/or one or more of the subaccounts, in
    accordance with the allocation instructions received from the
    Owner in the application.  At that time, the various loads,
    fees, charges and expenses will begin to be assessed.

    Policy 3

    The Owner determines in the application what portions, if
    any, of the premiums are to be allocated to each of the
    Subaccounts of the Variable Account, the Fixed Account or
    both.  Until the date that an application is approved by IDS
    Life's Home Office underwriting department, the premiums
    received by IDS Life are held in IDS Life's Fixed Account and
    interest at the current Fixed Account rate is credited on the
    net premiums (gross premium received minus the Premium
    Expense Charge).  As of the date that IDS Life's Home Office
    underwriting department approves the application, the net
    premiums plus interest accrued thereon will be allocated to
    the Fixed Account and/or one or more of the subaccounts, in
    accordance with the allocation instructions received from the
    Owner in the application.  At that time, the various loads,
    fees, charges and expenses will begin to be assessed.

16. Describe the procedure with respect to the acquisition of
    underlying securities and the disposition thereof, and state
    the substance of the provisions of any indenture or agreement
    pertaining thereto.

    Policy 1

    The Owner determines in the application what portions, if
    any, of the premium are to be allocated to each of the
    Subaccounts.  Until the date that a policy is mailed from IDS
    Life's Home Office for delivery to the Owner, the premium
    received by IDS Life is held in IDS Life's general account. 
    When a Policy is mailed, the Policy Value will reflect the
    performance of Subaccount R, which invests in the Money
    Market Portfolio of IDS Life Series Fund, from the date the
    premium was received.  On the date that a Policy is mailed
    from IDS Life's Home Office for delivery to the Owner, the
    Policy Value will be allocated to one or more of the
    Subaccounts in accordance with the allocation instructions
    received from the Owner in the application.  For amounts
    allocated to the Subaccounts, IDS Life applies the Policy<PAGE>
PAGE 42
    Value so allocated to the purchase of Fund shares or units of
    the Trust at their net asset value determined as of the end
    of the valuation period during which the written directions
    to make the allocation are received by IDS Life at its Home
    Office.  Fund shares or units of the Trust may be redeemed by
    IDS Life to permit the payment of insurance benefits, amounts
    requested for surrender, loan payments, interest charges on
    loans, surrender charges and fees and other purposes
    contemplated by the Policy.

    Policy 2

    The Owner determines in the application what portions, if
    any, of the premiums are to be allocated to each of the
    Subaccounts of the Variable Account, the Fixed Account or
    both.  Until the date that an application is approved by IDS
    Life's Home Office underwriting department, the premiums
    received by IDS Life are held in IDS Life's Fixed Account and
    interest at the current Fixed Account rate is credited on the
    net premiums (gross premium received minus the Premium
    Expense Charge).  As of the date that IDS Life's Home Office
    underwriting department approves the application, the net
    premiums plus interest accrued thereon will be allocated to
    the Fixed Account and/or one or more of the Subaccounts, in
    accordance with the allocation instructions received from the
    Owner in the application.  For amounts allocated to the
    Subaccounts, IDS Life applies the Policy Value so allocated
    to the purchase of Fund shares or units of the Trust at their
    net asset value determined as of the end of the Valuation
    Period during which the written directions to make the
    allocation are received by IDS Life at its Home Office.  Fund
    shares or units of the Trust may be redeemed by IDS Life to
    permit the payment of insurance benefits, amounts requested
    for surrender, loan payments, interest charges on loans,
    surrender charges and fees and other purposes contemplated by
    the Policy.

    Policy 3

    The Owner determines in the application what portions, if
    any, of the premiums are to be allocated to each of the
    Subaccounts of the Variable Account, the Fixed Account or
    both.  Until the date that an application is approved by IDS
    Life's Home Office underwriting department, the premiums
    received by IDS Life are held in IDS Life's Fixed Account and
    interest at the current Fixed Account rate is credited on the
    net premiums (gross premium received minus the Premium
    Expense Charge).  As of the date that IDS Life's Home Office
    underwriting department approves the application, the net
    premiums plus interest accrued thereon will be allocated to
    the Fixed Account and/or one or more of the Subaccounts, in
    accordance with the allocation instructions received from the
    Owner in the application.  For amounts allocated to the
    Subaccounts, IDS Life applies the Policy Value so allocated
    to the purchase of Fund shares or units of the Trust at their
    net asset value determined as of the end of the Valuation
    Period during which the written directions to make the<PAGE>
PAGE 43
    allocation are received by IDS Life at its Home Office.  Fund
    shares or units of the Trust may be redeemed by IDS Life to
    permit the payment of insurance benefits, amounts requested
    for surrender, loan payments, interest charges on loans,
    surrender charges and fees and other purposes contemplated by
    the Policy.

17. (a)  Describe the procedure with respect to withdrawal or
         redemption by security holders.

         Any surrender by an Owner may be made by a request in
         writing to the Home Office of IDS Life.  IDS Life will
         determine the Surrender Value as of the end of the
         Valuation Period during which the request is received. 
         See the response to item 13(a) for information
         concerning surrender charges and fees.  The Surrender
         Value will be paid within seven days after the Owner's
         written request is received by IDS Life at its Home
         Office, however IDS Life reserves the right to defer
         any payment of Surrender Value (1) which derives from a
         Premium Payment made by a check which has not cleared
         the banking system (good payment has been collected),
         or (2) if (a) the New York Stock Exchange is closed
         (other than customary weekend and holiday closings),
         (b) trading on the Exchange is restricted; (c) an
         emergency exists such that it is (b)not reasonably
         practical to dispose of securities held in the Variable
         Account or to determine the value of the Variable
         Account's net assets; or (d) the Securities and
         Exchange Commission by order so permits for the
         protection of security holders.  Conditions described
         in (b) and (c) will be decided by or in accordance with
         rules of the Securities and Exchange Commission.

         Any surrenders of the Policy Value from the Fixed
         Account may be postponed for up to 6 months, in Policy
         2 and in Policy 3.  If IDS Life postpones payment for
         more than 30 days, interest at an annual rate of 3
         percent will be paid on the amount surrendered for the
         period of postponement.

    (b)  Furnish the names of any persons who may redeem or
         repurchase, or are required to redeem or repurchase,
         the trust's securities or underlying securities from
         security holders, and the substance of the provisions
         of any indenture or agreement pertaining thereto.

         IDS Life is required to honor surrender requests as
         described in Items 10(c) and 17(a).

         The Fund is required to redeem Fund shares at net asset
         value at the request of IDS Life, and to make payment
         therefor to the Variable Account within seven days of
         the receipt of the redemption request.  The Trust is
         required to redeem Trust units at net asset value at
         the request of IDS Life, and to make payment therefor<PAGE>
PAGE 44
         to the Variable Account within seven days of the
         receipt of the redemption request.

    (c)  Indicate whether repurchased or redeemed securities
         will be canceled or may be resold.

         A totally surrendered Policy will be canceled.

18. (a)  Describe the procedure with respect to the receipt,
         custody and disposition of the income and other
         distributable funds of the trust and state the
         substance of the provisions of any indenture or
         agreement pertaining thereto.

         All income and other distributable funds of each
         Subaccount investing in the Fund are reinvested in
         shares of the appropriate Fund Portfolio and are added
         to the assets of that Subaccount.  For Trust units, all
         investment income and other distributions, if any, are
         held in the Trust.

    (b)  Describe the procedure, if any, with respect to the
         reinvestment of distributions to security holders and
         state the substance of the provisions of any indenture
         or agreement pertaining thereto.

         Not applicable.

    (c)  If any reserves or special funds are created out of
         income or principal, state with respect to each such
         reserve or fund the purpose and ultimate disposition
         thereof, and describe the manner of handling the same.

         At the present time, IDS Life does not intend to
         establish any reserves for federal income taxes which
         may be attributable to the Variable Account.

    (d)  Submit a schedule showing the periodic and special
         distributions which have been made to security holders
         during the three years covered by the financial
         statements filed here with.  State for each such
         distribution the aggregate amount and amount per share. 
         If distributions from sources other than current income
         have been made, identify each such other source and
         indicate whether such distribution represents the
         return of principal payments to security holders.  If
         payments other than cash were made, describe the nature
         thereof.

         Not applicable.

19. Describe the procedure with respect to keeping of records and
    accounts of the trust, the making of reports and the
    furnishing of information to security holders, and the
    substance of the provisions of any indenture or agreement
    pertaining thereto.
<PAGE>
PAGE 45
    IDS Life has primary responsibility for all administration of
    the Policy and will maintain the records and books of the
    Variable Account.

    Included in these records are the name, address, taxpayer
    identification number and other pertinent information for
    each Owner, and the number and Policy Value records of each
    Policy.  IDS Life will also keep, as custodian, the records
    of all securities transactions entered into with the Fund and
    the Trust for the purchase and sale of the Fund shares or
    Trust units by the Variable Account.

20. State the substance of the provisions of any indenture or
    agreement concerning the trust with respect to the following:

    (a)  Amendments to such indenture or agreement.

         Not applicable.

    (b)  The extension or termination of such indenture or
         agreement.

         Not applicable.

    (c)  The removal or resignation of the trustee or custodian,
         or the failure of the trustee or custodian, or the
         failure of the trustee or custodian to perform its
         duties, obligations and functions.

         Not applicable.

    (d)  The appointment of a successor trustee and the
         procedure if a successor trustee is not appointed.

         Not applicable.

    (e)  The removal or resignation of the depositor, or the
         failure of the depositor to perform its duties,
         obligations and functions.

         There are no provisions relating to the appointment of
         a successor depositor.

    (f)  The appointment of a successor depositor and the
         procedure if a successor depositor is not appointed.

         There are no provisions regarding the removal or
         resignation of IDS Life, nor its failure to perform its
         duties, obligations, and functions as depositor.

21. (a)  State the substance of the provisions of any indenture
         or agreement with respect to loans to security holders.

         Policy 1

         After the first Policy Year, the Owner may obtain a
         loan from the Company by sending a Written Request. <PAGE>
PAGE 46
         The loan value of the Policy is the only security
         required.  The policy loan rate is 5.0% per annum
         payable in advance.  The Owner may borrow an amount up
         to 90% of the total Policy Value less Surrender
         Charges.  Interest to pay for the loan until the next
         policy anniversary will be included in determining the
         maximum loan value.  IDS Life will compute the Loan
         Value as of the end of the Valuation Period during
         which the loan request is received at its Home Office.

         The Loan Value of the Variable Account will be paid
         within seven days after the Owner's written request is
         received by IDS Life at its Home Office, however IDS
         Life reserves the right to defer any payment of Loan
         Value (1) which derives from a Premium Payment made by
         a check which has not cleared the banking system (good
         payment has been collected), or (2) if (a) the New York
         Stock Exchange is closed (other than customary weekend
         and holiday closings), (b) trading on the Exchange is
         restricted; (c) an emergency exists such that it is not
         reasonably practical to dispose of securities held in
         the Account or to determine the value of the Account's
         net assets; or (d) the Securities and Exchange
         Commission by order so permits for the protection of
         security holders.  Conditions described in (b) and (c)
         will be decided by or in accordance with the rules of
         the Securities and Exchange Commission.

         Policy 2

         The Owner may obtain a loan from the Company by sending
         a Written Request.  The loan value of the Policy is the
         only security required.  The policy loan rate is 6.1
         percent per annum payable in advance.  For policies
         purchased on or after May 1, 1993 (October 1, 1993 for
         New Jersey), IDS Life expects to reduce the loan 
         interest rate after a policy's 10th anniversary to 4.3%
         payable in advance.  The Owner may borrow an amount up
         to 85 percent of the total Policy Value less Surrender
         Charges.  Interest to pay for the loan until the next
         policy anniversary will be included in determining the
         maximum loan value.  IDS Life will compute the Loan
         Value as of the end of the Valuation Period during
         which the loan request is received at its Home Office. 
         The Owner also may request a loan by calling IDS Life. 
         IDS Life has the authority to honor any telephone loan
         request believed to be authentic.  IDS Life is not
         responsible for determining the authenticity of such
         calls.  A loan request received before 3 p.m. Central
         time (which is 4 p.m. New York time) will be processed
         the same day.

         The Loan Value of the Variable Account will be paid
         within seven days after the Owner's written request is
         received by IDS Life at its Home Office, however IDS
         Life reserves the right to defer any payment of Loan
         Value (1) which derives from a Premium Payment made by<PAGE>
PAGE 47
         a check which has not cleared the banking system (good
         payment has been collected), or (2) if (a) the New York
         Stock Exchange is closed (other than customary weekend
         and holiday closings), (b) trading on the Exchange is
         restricted; (c) an emergency exists such that it is not
         reasonably practical to dispose of securities held in
         the Account or to determine the value of the Account's
         net assets; or (d) the Securities and Exchange
         Commission by order so permits for the protection of
         security holders.  Conditions described in (b) and (c)
         will be decided by or in accordance with rules of the
         Securities and Exchange Commission.  Any loans from the
         Fixed Account may be delayed up to six months from the
         date IDS Life receives the request.

         Policy 3

         Policy loans

         The owner may borrow against their policy by written or
         telephone request.  A loan request received before
         close of business will be processed the same day.  A
         request received after close of business will be
         processed the following business day.  (Loans by
         telephone are limited to $50,000).

         Interest rate:  The interest rate for policy loans is
         6% per year.  After the policy's 10th anniversary we
         expect to reduce the loan interest rate to 4% per year. 
         Interest is charged daily and due at the end of the
         policy year.

         Minimum loan:  $500 ($200 for Connecticut residents) or
         the remaining loan value, whichever is less.

         Maximum loan:  
   
              o  In Texas, 100% of the policy value in the
              fixed account, minus a pro rata portion of
              surrender charges.
              o  In Virginia, 90% of the policy value minus
              surrender charges.
              o  In Alabama, 100% of the policy value minus
              surrender charges.
              o  In all other states, 85% of the policy value
              minus surrender charges.
       
         IDS Life will compute the maximum loan value as of the
         end of the valuation period during which we receive
         your loan request.  The amount available at any time
         for a new loan is the maximum loan value less any
         existing indebtedness.  In doing so, IDS Life reserves
         the right to deduct from the loan value interest for
         the period until the next policy anniversary and
         monthly deductions that will be taken until the next
         policy anniversary.
    <PAGE>
PAGE 48
         Payment of loaned funds:  Generally, IDS Life will pay
         loans within seven days after IDS Life receives the
         owner's request (with certain exceptions -- see
         "Deferral of payments," under "Payment of policy
         proceeds").
   
         Repayments:  Loan repayments will be allocated to
         subaccounts and/or the fixed account using the premium
         allocation percentages in effect unless the owner tells
         IDS Life otherwise.  Repayments must be in amounts of
         at least $50.
    
         Deferral of payments:  
   
         IDS Life reserves the right to defer payments of policy
         loans if:
    
              o  the payments derive from a premium payment
              made by a check that has not cleared the banking
              system (good payment has not been collected);
              o  the NYSE is closed (other than customary
              weekend and holiday closings);
              o  in accordance with SEC rules, trading on the
              NYSE is restricted or, because of an emergency,
              it is not practical to dispose of securities held
              in the subaccount or determine the value of the
              subaccount's net assets.
   
         Any loans from the fixed account may be delayed up to
         six months from the date IDS Life receives the request. 
         If IDS Life postpones the payment of surrender proceeds
         more than 30 days, IDS Life will pay the owner interest
         on the amount surrendered at an annual rate of 3% for
         the period of postponement.
    
    (b)  Furnish a brief description of any procedure or
         arrangement by which loans are made available to
         security holders by the depositor, principal
         underwriter, trustee or custodian, or any affiliated
         person of the foregoing.

         Policy 1

         If it is not specified from which Subaccounts the loan
         is to be made, the loan will be made from the
         Subaccounts in the same proportion as the value in each
         Subaccount bears to the total Policy Value, less
         Indebtedness.

         A loan from the Subaccounts will result in Accumulation
         Units being redeemed and the Proceeds transferred from
         the Subaccounts into IDS Life's General Account. 
         Repayments will be transferred into the Subaccounts. 
         Loan repayments must be in amounts of at least $50. 
         Loan repayments will be allocated to the Subaccounts<PAGE>
PAGE 49
         using the premium allocation percentages in effect
         unless the Owner tells IDS Life otherwise.

         If additional interest accrues to the Policy loan and
         is not paid when due, IDS Life will increase the amount
         of Indebtedness in the General Account to cover the
         amount of such additional interest.  The interest added
         to a Policy loan will be charged the same interest rate
         as the loan.  IDS Life will allocate the amount of the
         additional interest among the Subaccounts, using the
         monthly deduction allocation percentages.  If the value
         in any one of the Subaccounts is insufficient to pay
         the additional interest so allocated, the entire
         additional interest will be deducted from each of the
         Subaccounts in the same proportion as the value in each
         Subaccount bears to the total Policy Value less
         Indebtedness.

         IDS Life will credit the loaned amount with 4% annual
         interest.

         Policy 2

         If it is not specified whether the loan is to be made
         from the Fixed Account or the Subaccounts, the loan
         will be made from the subaccounts and the Fixed Account
         in the same proportion as the value in each subaccount
         and the Fixed Account bears to the total policy value,
         less indebtedness.

         A loan from the subaccounts will result in accumulation
         units being redeemed and the proceeds transferred from
         the subaccounts into IDS Life's fixed account. 
         Repayments will be transferred into the Fixed Account
         and/or the subaccounts.  Loan repayments must be in
         amounts of at least $25.  Loan repayments will be
         allocated to subaccounts and/or the Fixed Account using
         the premium allocation percentages in effect unless the
         Owner tells IDS Life otherwise.

         If additional interest accrues to the Policy loan and
         is not paid when due, IDS Life will increase the amount
         of indebtedness in the fixed account to cover the
         amount of such additional interest.  The interest added
         to a policy loan will be charged the same interest rate
         as the loan.  IDS Life will allocate the amount of the
         additional interest among the Fixed Account and/or the
         subaccounts, using the monthly deduction allocation
         percentages.  If the value in the Fixed Account or any
         one of the subaccounts is insufficient to pay the
         additional interest so allocated, the entire additional
         interest will be deducted from the Fixed Account and
         each of the subaccounts in the same proportion as the
         value in the Fixed Account and each subaccount bears to
         the total policy value, less indebtedness.
<PAGE>
PAGE 50
         IDS Life will credit the loaned amount with 4.50
         percent annual interest.

         Policy 3

         Allocation of loans to accounts:  If the owner does not
         specify whether the loan is to come from the fixed
         account or the subaccounts, it will be made from the
         subaccounts and the fixed account in proportion to
         their values, minus indebtedness.  When a loan is made
         from a subaccount, accumulation units are redeemed and
         the proceeds transferred into the fixed account.  IDS
         Life will credit the policy value loaned with 4% annual
         interest.  (See Repayments Section under 21(a) Policy
         3).

         Overdue interest:  If accrued interest is not paid when
         due, IDS Life will increase the amount of indebtedness
         in the fixed account to cover the amount due.  Interest
         added to a policy loan will be charged the same
         interest rate as the loan itself.  IDS Life will take
         such interest from the fixed account and/or
         subaccounts, using the monthly deduction allocation
         percentages.  If the value in the fixed account or any
         subaccount is not enough to pay the interest so
         allocated, all of the interest will be taken from all
         of the accounts in proportion to their value, minus
         indebtedness.

         Effects of policy loans:  If the owner does not repay
         their loan, it will reduce the death benefit and policy
         value.  Even if the owner does repay it, their loan can
         have a permanent effect on death benefits and policy
         values, because money borrowed against the subaccounts
         will not share in the investment results of the
         relevant portfolio(s).  A loan may terminate the DBG-85
         or the DBG-100.  The loan amount is deducted from the
         total premiums paid, which may reduce the total below
         the level required to keep the DBG-85 or the DBG-100 in
         effect.

    (c)  If such loans are made, furnish the aggregate amounts
         of loans outstanding at the end of the last fiscal
         year, the amount of interest collected during the last
         fiscal year allocated to the depositor, principal
         underwriter, trustee or custodian or affiliated person 
         of the foregoing and the aggregate amount of loans in
         default at the end of the last fiscal year covered by
         financial statements filed herewith.

         For Policy 1, the outstanding loan balance for fiscal
         year 1994 was $3,958,124.51 and the amount of interest
         collected was $152,783.38.
<PAGE>
PAGE 51
         For Policy 2, the outstanding loan balance for fiscal
         year 1994 was $17,676,895.43 and the amount of interest
         collected was $1,064,190.32.  

         No loans were in default for Policy 1 or Policy 2.

22. State the substance of the provisions of any indenture or
    agreement with respect to limitations on the liabilities of
    the depositor, trustee or custodian, or any other party to
    such indenture or agreement.

    Not applicable.

23. Describe any bonding arrangement for officers, directors,
    partners or employees of the depositor or principal
    underwriter of the trust, including the amount of coverage
    and the type of bond.
   
    The officers, employees and sales force of IDS Life are
    bonded in the amount of $100 million, by virtue of a blanket
    fidelity bond issued by Saint Paul Fire and Marine to IDS
    Life's parent, American Express Financial Corporation.  
    Saint Paul Fire and Marine provides the first $30 million. 
    An additional $15 million in fidelity coverage is extended by
    a second policy issued by Vigilant Insurance Co. to the
    directors, officers, and employees of IDS Life.  An
    additional $20 million in fidelity coverage is extended by a
    third policy issued by National Union to the directors,
    officers, and employees of IDS Life.  An additional $4
    million in fidelity coverage is extended by a fourth policy
    issued by Saint Paul Fire and Marine to the directors,
    officers, and employees of IDS Life.  An additional $11.5
    million in fidelity coverage is extended by a fifth policy
    issued by Continental to the directors, officers, and
    employees of IDS Life.  An additional $12.5 million in
    fidelity coverage is extended by a sixth policy issued by
    Gulf Insurance Company to the directors, officers, and
    employees of IDS Life.  An additional $7 million in fidelity
    coverage is extended by a final policy issued by Reliance
    Insurance Company to the directors, officers and employees of
    IDS Life.
    
24. State the substance of any other material provisions of any
    indenture or agreement concerning the trust or its securities
    and a description of any other material functions or duties
    of the depositor, trustee or custodian not stated in Item 10
    or Items 14 to 23 inclusive.

    The Owner may assign the Policy at any time.  No such
    assignment is effective as to IDS Life, however, unless it is
    filed with IDS Life at its Home Office for recording.
<PAGE>
PAGE 52
III.

ORGANIZATION, PERSONNEL AND AFFILIATED PERSONS OF DEPOSITOR

Organization and Operations of Depositor

25. State the form or organization of the depositor of the trust,
    the name of the state or other sovereign power under the laws
    of which the depositor was organized and the date of
    organization.  

    IDS Life is a stock life insurance company organized under
    Minnesota law on August 7, 1957.  Prior to April 2, 1973, IDS
    Life was called Investors Syndicate Life Insurance and
    Annuity Company.

26. (a)  Furnish the following information with respect to all
         fees received by the depositor of the trust in
         connection with the exercise of any functions or duties
         concerning securities of the trust during the period
         covered by the financial statements filed herewith.
   <TABLE><CAPTION>
                    Total                                                                Aggregate gross    
                   purchase                     Amount of     Amount of                     amount of
                   payments     Amount of    administration   management     Amount of     load, fees, 
                 by security    sales load        fees           fees        other fees        etc.
Year               holders       received       received       received       received       received
<S>             <C>             <C>           <C>                 <C>         <C>          <C>      
Policy 1 and 2
1992            $ 48,998,425    $3,649,836    $16,107,910         --          $59,055      $ 68,815,226
1993              69,454,041     4,408,562     22,722,261         --           63,068        96,647,932
1994             117,787,027     6,969,493     34,835,904         --           63,193       159,654,617

Policy 3
Not Applicable
</TABLE>    

    (b)  Furnish the following information with respect to any
         fee or any participation in fees received by the
         depositor from any underlying investment company or any
         affiliated person or investment adviser of such
         company.
   
         The underlying investment company, IDS Life Series
         Fund, Inc., pays IDS Life for managing its portfolio,
         providing administrative services, and serving as
         transfer agent.  For fiscal year 1994, the aggregate
         amount of this management fee was $2,087,292.
    
27. Describe the general character of the business engaged in by
    the depositor including a statement as to any business other
    than that of depositor of the trust.  If the depositor acts
    or has acted in any capacity with respect to any investment
    company or companies other than the trust, state the name or
    names of such company or companies, their relationship, if
    any, to the trust, and the nature of the depositor's
    activities therewith.  If the depositor has ceased to act in
    such named capacity, state the date of and circumstances
    surrounding cessation.
<PAGE>
PAGE 53
    IDS Life conducts a conventional life insurance business in
    addition to a variable annuity business.  IDS Life conducts
    this business in 49 states and the District of Columbia.  A
    wholly owned subsidiary of IDS Life, IDS Life Insurance
    Company of New York, conducts a substantially identical
    business in New York.  A wholly owned subsidiary of IDS Life,
    American Enterprise Life, conducts a substantially identical
    business in District of Columbia and in all states except
    Maine, New Hampshire, New York, Vermont and Wyoming.

    IDS Life is investment manager and underwriter of IDS Life
    Variable Annuity Fund A and IDS Life Variable Annuity Fund B,
    both of which are registered management investment companies.

    IDS Life is also the investment manager and underwriter of
    IDS Life Investment Series, Inc.  IDS Life Special Income
    Fund, Inc., IDS Life Moneyshare Fund, Inc., and IDS Life
    Managed Fund, Inc.

    These funds support a number of unit investment trusts
    sponsored by IDS Life and its affiliates.

Officials and Affiliated Persons of Depositor

28. (a)  Furnish as at latest practicable date the following
         information with respect to the depositor of the trust,
         with respect to each officer, director, or partner of
         the depositor, and with respect to each natural person
         directly or indirectly owning, controlling or holding
         with Power to vote 5% or more of the outstanding voting
         securities of the depositor.

         Not applicable.

    (b)  Furnish a brief statement of the business experience
         during the last five years of each officer, director or
         partner of the depositor.

Directors.

The directors of IDS Life, together with their principal occupation
during the last five years, are shown below.
   
Name and Address                  Principal Occupation

David R. Hubers                   Director since September 1989;
IDS Tower 10                      president and chief executive
Minneapolis, MN                   officer, American Express 
                                  Financial Corporation (AEFC), 
                                  since January 1984.  Senior 
                                  vice president, finance and
                                  chief financial officer, AEFC,    
                                  from January 1984 to August 1993.
<PAGE>
PAGE 54
Richard W. Kling                  Director since February 1984;     
IDS Tower 10                      president since March 1994.       
Minneapolis, MN                   Executive vice president,         
                                  Marketing and Products from       
                                  January 1988 to March 1994.       
                                  Vice president, AEFC, since       
                                  January 1988.  Director of IDS    
                                  Life Series Fund, Inc. and        
                                  manager of IDS Life Variable
                                  Annuity Funds A and B.

Paul F. Kolkman                   Director since May 1984;          
IDS Tower 10                      executive vice president since    
Minneapolis, MN                   March 1994; vice president,       
                                  Finance from May 1984 to March    
                                  1994; vice president, AEFC, 
                                  since January 1987.
 
Peter A. Lefferts                 Director and executive vice       
IDS Tower 10                      president, Marketing since March  
Minneapolis, MN                   1994; senior vice president and   
                                  director, AEFC, since February    
                                  1986.

Janis E. Miller                   Director and executive vice       
IDS Tower 10                      president, Variable Assets since  
Minneapolis, MN                   March 1994; vice president,       
                                  AEFC, since June 1990.  Director, 
                                  Mutual Funds Product Development  
                                  and Marketing, AEFC, from May     
                                  1987 to May 1990.  Director of    
                                  IDS Life Series Fund, Inc. and    
                                  manager of IDS Life Variable      
                                  Annuity Funds A and B.

James A. Mitchell                 Chairman of the board since March
IDS Tower 10                      1994; director since July 1984;   
Minneapolis, MN                   chief executive officer since     
                                  November 1986; 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                   Director and executive vice       
IDS Tower 10                      president, Client Service, since  
Minneapolis, MN                   March 1994; senior vice
                                  president, Operations, Travel
                                  Related Services (TRS), a
                                  subsidiary of American Express
                                  Company, since July 1992; vice
                                  president, TRS, from November
                                  1989 to July 1992; chief<PAGE>
PAGE 55
                                  operating officer, TRS,
                                  from March 1988 to November 1989.

Stuart A. Sedlacek                Director and executive vice       
IDS Tower 10                      president, Assured Assets since   
Minneapolis, MN                   March 1994; vice president, AEFC, 
                                  since September 1988.
    
Melinda S. Urion                  Director and controller since     
                                  September 1991; executive vice    
                                  president since March 1994; vice  
                                  president and treasurer from      
                                  September 1991 to March 1994;     
                                  vice president, AEFC, since       
                                  September 1991; chief             
                                  accounting officer, AEFC, from    
                                  July 1988 to September 1991.

Principal Officers.

The following are principal officers of IDS Life.  Each officer
serves at the pleasure of the Board of Directors.

Morris Goodwin Jr.
Vice president and treasurer since March 1994; vice president and
corporate treasurer, AEFC, since July 1989; chief financial officer
and treasurer, IDS Bank & Trust, from January 1988 to July 1989.
    
William A. Stoltzmann
Vice President, General Counsel and Secretary since 1985.

Companies Owning Securities of Depositor

29. Furnish as at latest practicable date the following
    information with respect to each Company which directly or
    indirectly owns, controls or holds with power to vote 5% or
    more of the outstanding voting securities of the depositor.
    IDS Life, a Minnesota corporation, is a wholly owned
    subsidiary of American Express Financial Corporation;
    American Express Financial Corporation, a Delaware
    corporation, is a wholly owned subsidiary of American Express
    Company, American Express Tower, World Financial Center, New
    York, New York 10285.

Controlling Persons

30. Furnish as at latest practicable date the following
    information with respect to any person, other than those
    covered by Items 28, 29 and 42 who directly or indirectly
    controls the depositor.

    None.
<PAGE>
PAGE 56
Compensation of Officers and Directors of Depositor Compensation of
Officers of Depositor

31. Furnish the following information with respect to the
    remuneration for services paid by the depositor during the
    last fiscal year covered by financial statements filed
    herewith:

    (a)  directly to each of the officers or partners of the
         depositor directly receiving the three highest amounts
         of remuneration:

         To be filed by amendment.

    (b)  directly to all officers or partners of the depositor
         as a group exclusive of persons whose remuneration is
         included under Item 31(a), stating separately the
         aggregate amount paid by the depositor itself and the
         aggregate amount paid by all the subsidiaries:

         To be filed by amendment.

    (c)  indirectly or through subsidiaries to each of the
         officers or partners of the depositor:

         To be filed by amendment.

Compensation of Directors

32. Furnish the following information with respect to the
    remuneration reported under Item 31, paid by the depositor
    during the last fiscal year covered by financial statements
    filed herewith:

    (a)  the aggregate direct remuneration to directors:

         To be filed by amendment.

    (b)  indirectly or through subsidiaries to directors:

         To be filed by amendment.

33. (a)  Furnish the following information with respect to the
         aggregate amount of remuneration for services of all
         employees of the depositor (exclusive of persons whose
         remuneration is reported in Items 31 and 32) who
         received remuneration in excess of $10,000 during the
         last fiscal year covered by financial statements filed
         herewith from the depositor and any of its
         subsidiaries.

         Not applicable - see Item 31.

    (b)  Furnish the following information with respect to
         remuneration for services paid directly during the last
         fiscal year covered by financial statements filed
         herewith to the following classes of persons (exclusive<PAGE>
PAGE 57
         of those persons covered by Item 33(a)): (1) sales
         managers, branch managers, district managers and other
         persons supervising the sale of registrant's
         securities; (2) salesmen, sales agents, canvassers and
         other persons making solicitations but not ln
         supervisory capacity; (3) administrative and clerical
         employees; and (4) others (specify).  If a person is
         employed in more than one capacity, classify according
         to the predominant type of work.

         Not applicable - see Item 31.

Compensation to Other Persons

34. Furnish the following information with respect to the
    aggregate amount of compensation for services paid any
    persons (exclusive of persons whose remuneration is reported
    in Items 31, 32 and 33), whose aggregate compensation in
    connection with services rendered with respect to the trust
    in all capacities exceed $10,000 during the last fiscal year
    covered by financial statements filed herewith from the
    depositor and any of its subsidiaries.

    Not applicable - see Item 31.

                          IV.

DISTRIBUTION AND REDEMPTION OF SECURITIES

Distribution of Securities

35. Furnish the names of the states in which sales of the trust's
    securities (A) are currently being made, (B) are presently
    proposed to be made, and (C) have been discontinued,
    indicating by appropriate letter the status with respect to
    each state.
       
   
    IDS Life no longer sells Policy 1.  IDS Life currently sells
    Policy 2, and intends to sell Policy 3 in the District of
    Columbia and all states except New York.
    
36. If sales of the trust's securities have at any time since
    January 1, 1936 been suspended for more than a month,
    describe briefly the reasons for such suspension.

    Not applicable.

37. (a)  Furnish the following information with respect to each
         instance where subsequent to January 1, 1937, any
         Federal or state governmental officer, agency or
         regulatory body denied authority to distribute
         securities of the trust, excluding a denial which was
         merely a procedural step prior to any determination by
         such officer, etc., and which denial was subsequently
         rescinded.
<PAGE>
PAGE 58
         (1)  Name of officer, agency or body.

         (2)  Date of denial.

         (3)  Brief statement of reasons given for denial.

              Not applicable.

    (b)  Furnish the following information with regard to each
         instance where, subsequent to January 1, 1937, the
         authority to distribute securities of the trust has
         been revoked by any Federal or state governmental
         officer, agency or regulatory body.

         (1)  Name of officer, agency or body.

         (2)  Date of revocation.

         (3)  Brief statement of reason given for revocation.

              Not applicable.

38. (a)  Furnish a general description of the method of
         distribution of securities of the trust.

         IDS Life may be deemed to be the principal underwriter
         of the Policy and will perform all sales and
         administrative duties.  IDS Life will distribute the
         Policy exclusively through a sales force it shares with
         American Express Financial Advisors Inc.  IDS Life is
         itself a registered broker/dealer, and is a member of
         the National Association of Securities Dealers, Inc.
         (NASD).  Members of the IDS Life sales force are
         trained and licensed to sell both the conventional
         insurance products of the Company, as well as its
         variable life insurance and annuity contracts.

    (b)  State the substance of any current selling agreement
         between each principal underwriter and the trust or the
         depositor, including a statement as to the inception
         and termination dates of the agreement, any renewal and
         termination provisions, and any assignment provisions.

         Not applicable.

    (c)  State the substance of any current agreement or
         arrangements of each principal underwriter with
         dealers, agents, salesmen, etc., with respect to
         commissions, and overriding commissions, territories,
         franchises, qualifications and revocations.  If the
         trust is the issuer of periodic payment plan
         certificates, furnish schedules of commissions and the
         bases thereof.  In lieu of a statement concerning
         schedules of commissions, such schedules of commissions
         may be filed as Exhibit A(3)(c).
<PAGE>
PAGE 59
         Policy 1

         IDS Life will pay a commission not to exceed 3% of the
         single premium in the first Policy Year, .10% of the
         single premium in the Second Policy Year, .20% of the
         single premium in the third Policy Year, .30% of the
         single premium in the fourth Policy Year, and .05% of
         the Policy Value in Policy Years 5 through 11, to its
         sales representatives for sales of the Policy, if the 
         Policy is not lapsed, surrendered or terminated as a
         result of the Insured's death.  IDS Life will also pay
         on an approximate basis a total of 27% of the selling
         representative's commission to the Divisional and
         District Sales Managers of the selling representative.

         Policy 2

         IDS Life will pay a commission of up to 50 percent of
         the Initial Minimum Monthly Premium (annualized) when
         the Policy is sold, plus up to 3 percent of all
         premiums in excess of twelve times the Minimum Monthly
         Premium.  At the end of policy years 4 through 10, IDS
         Life will pay .05 percent of the policy value, net of
         indebtedness Additional commissions will be paid if an
         increase in coverage occurs.  IDS Life will also pay
         approximately 27 percent of the total representative's
         commission to the Division and District Sales Managers
         of the selling representative.

         Policy 3
   
         IDS Life will pay a commission of up to 50 percent of
         the Initial Target Premium (annualized) when the policy
         is sold, plus 2 percent of all premiums in excess of
         the target premium.  Each calendar quarter the policy
         is in force, IDS Life will pay .03125 percent of the
         policy value, net of indebtedness.  IDS Life will also
         pay approximately 17 percent of the total
         representative's commission to the Division and Sales
         Managers of the selling representative.
    
Information Concerning Principal Underwriter

39. (a)  State the form of organization of each principal
         underwriter of securities of the trust, the name of the
         state or other sovereign power under the laws of which
         each underwriter was organized and the date of
         organization.

         See Item 25.

    (b)  State whether any principal underwriter currently
         distributing securities of the trust is a member of the
         National Association of Securities Dealers, Inc.

         IDS Life is a member of the NASD.
<PAGE>
PAGE 60
40. (a)  Furnish the following information with respect to all
         fees received by each principal underwriter of the
         trust from the sale of securities of the trust and any
         other functions in connection therewith exercised by
         such underwriter in such capacity or otherwise during
         the period covered by the financial statement filed
         herewith.

         See Item 26(a).

    (b)  Furnish the following information with respect to any
         fee or any participation in fees received by each
         principal underwriter from any underlying investment
         company or any affiliated person or investment adviser
         of such company:

         (1)  The nature of such fee or participation.

         (2)  The name of the person making payment.

         (3)  The nature of the services rendered in
              consideration for such fee or participation.

         (4)  The aggregate amount received during the last
              financial year covered by the financial
              statements filed herewith.
   
              See Item 26(b).
    
41. (a)  Describe the general character of the business engaged
         in by each principal underwriter, including a statement
         as to any business other than the distribution of
         securities of the trust.  If a principal underwriter
         acts or has acted in any capacity with respect to any
         investment company or companies, their relationship, if
         any, to the trust and the nature of such activities. 
         If a principal underwriter has ceased to act in such
         named capacity, state the date of and circumstances
         surrounding such cessation.
   
         See Item 27.
    
    (b)  Furnish as at latest practicable date the address of
         each branch office of each principal underwriter
         currently selling securities of the trust and furnish
         the name and residence address of the person in charge
         of such office.

         Not applicable.

    (c)  Furnish the number of individual salesmen of each
         principal underwriter through whom any of the
         securities of the trust were distributed for the last
         fiscal year of the trust covered by the financial
         statements filed herewith by such salesmen in such
         year.
<PAGE>
PAGE 61
         Not applicable.

42. Furnish as at latest practicable date the following
    information with respect to each principal underwriter
    currently distributing securities of the trust and with
    respect to each of the officers, directors or partners of
    such underwriter.
   
    Not Applicable.
    
43. Furnish, for the last fiscal year covered by the financial
    statements filed herewith, the amount of brokerage
    commissions received by any principal underwriter who is a
    member of a national securities exchange and who is currently
    distributing the securities of the trust or effecting
    transactions for the trust in the portfolio securities of the
    trust.
   
    Not Applicable.
    
44. (a)  Furnish information with respect to the method of
         valuation used by the trust for purposes of determining
         the offering price to the public of securities issued
         by the trust or the valuation of shares or interests in
         the underlying securities acquired by the holder of a
         periodic payment plan certificate.

         Policy 1

         The Net Premium allocated to the Subaccounts will be
         invested at net asset value in any one or more of the
         Fund Portfolios in accordance with the selection made
         by the Owner.  Fund shares so purchased become assets
         of the Variable Account.

         Upon allocation to the appropriate Subaccount(s), the
         policy value is converted into Accumulation Units of
         the Subaccount.  The number of Accumulation Units to be
         credited to the Policy is determined by dividing the
         policy value by the Accumulation Unit Value as of the
         end of the Valuation Period during which the Policy
         Value was allocated to the subaccount.  The same
         calculation will apply to amounts transferred from any
         other Subaccount.  The net investment results of each
         Subaccount vary with the investment performance of the
         Fund Portfolio or valuation of the units of the Trust
         in which the Subaccount invests.

         Policy Values for the Subaccounts are determined by
         multiplying the number of Accumulation Units credited
         to the Subaccounts by the appropriate current
         Accumulation Unit Value(s).  The value of the
         Accumulation Unit for each of the Subaccounts was
         arbitrarily set initially at $1.00.  Units of each
         Trust will be valued at the "Sponsor's Repurchase
         Price" as defined in the prospectus for the Trust.  The
         value of an Accumulation Unit for any of the<PAGE>
PAGE 62
         Subaccounts for any Valuation Period is determined by
         multiplying that Subaccount's Accumulation Unit Value
         for the immediately preceding Valuation Period by the
         Net Investment Factor for the Valuation Period for
         which the Accumulation Unit Value is being calculated.

         The Net Investment Factor for any Subaccount for any
         Valuation Period is determined by dividing (1) by (2)
         and subtracting (3) from the result:

         Where:

         (1)  is the net result of:

              (a)  the net asset value per share of the
                   Portfolio or value of units of the Trust
                   held in the Subaccount determined at the
                   end of the current Valuation Period, plus

              (b)  the per share amount of any dividend of
                   capital gain distribution made by the
                   Portfolio held in the Subaccount if the ex-
                   dividend date occurs during the current
                   Valuation Period, plus or minus

              (c)  a charge or credit for any taxes reserved
                   for, which is determined by IDS Life to
                   have resulted from the investment
                   operations of the Subaccount.

         (2)  is the net result of:

              (a)  the net asset value per share of the
                   Portfolio or value of units of the Trust
                   held in the Subaccount determined as of the
                   end of the immediately preceding Valuation
                   Period, plus or minus

              (b)  the charge or credit for any taxes reserved
                   for in the immediately preceding Valuation
                   Period.

         (3)  is the percentage factor representing the
              mortality and expense risk charge and the minimum
              death benefit guarantee risk charge.  Such factor
              is equal on an annual basis to .65% of the daily
              net asset value of the Subaccount.  In addition,
              for subaccounts investing in one or more Trusts,
              this factor will include a daily asset charge to
              reimburse IDS Life for the transaction charge
              which it has paid to Smith Barney, Inc.  The
              transaction charge is currently .25 percent and
              is guaranteed to never exceed .50 percent.
<PAGE>
PAGE 63
         Policy 2

         The Owner determines in the application what portions,
         if any, of the premiums are to be allocated to the
         Fixed Account and/or to each of the subaccounts.  Until
         the date that an application is approved by IDS Life's
         home office underwriting department, the premiums
         received by IDS Life are held in IDS Life's Fixed
         Account and interest at the current Fixed Account rate
         is credited on the net premiums (gross premium received
         minus the Premium Expense Charge).  As of the date that
         IDS Life's home office underwriting department approves
         the application, the net premiums plus interest accrued
         thereon will be allocated to the Fixed Account and/or
         one or more of the subaccounts, in accordance with the
         allocation instructions received from the Owner in the
         application.  At that time, the various loads, fees,
         charges and expenses will begin to be assessed.

         Upon allocation to the appropriate subaccounts, the
         policy value in the Subaccounts is converted into
         accumulation units of the subaccount.  The number of
         accumulation\units to be credited to the Policy is
         determined by dividing the policy value in the
         Subaccount by the accumulation unit value of that
         Subaccount as of the end of the valuation period during
         which the policy value was allocated to the respective
         subaccounts.  When amounts are transferred between the
         subaccounts, the accumulation units in the first
         subaccount will be reconverted into a cash value by
         multiplying the accumulation unit value by the number
         of accumulation units necessary to equal the amount to
         be transferred.  The amount transferred will then be
         converted into accumulation units of the second
         subaccount.

         The investment experience of a subaccount reflects
         increases or decreases in the net asset value of the
         underlying fund shares or in the value of units of the
         Trust and any charges against the assets in each
         subaccount.  Policy values for the subaccounts are
         determined by multiplying the number of accumulation
         uits credited to the subaccounts by the appropriate
         current accumulation unit value(s).  The value of the
         accumulation unit for each of the subaccounts was
         arbitrarily set initially at $1.  Units of each Trust
         will be valued at the "Sponsor's Repurchase Price" as
         defined in the prospectus for the Trust.

         The value of an accumulation unit for any of the
         subaccounts for any valuation period is determined by
         multiplying that subaccount's accumulation unit value
         for the immediately preceding valuation period by the
         Net Investment Factor for the valuation period for
         which the accumulation unit value is being calculated.
<PAGE>
PAGE 64
         The Net Investment Factor for any subaccount investing
         in any portfolio of the Fund or in any Trust for any
         valuation period is determined by dividing (1) by (2)
         and subtracting (3) from the result where:

         (1)  is the net result of:

              (a)  the net asset value per share of the
                   portfolio or the value of a unit of the
                   Trust held in the subaccount determined at
                   the end of the current valuation period,
                   plus

              (b)  the per share amount of any dividend or
                   capital gain distribution made by the
                   portfolio held in the subaccount if the ex-
                   dividend date occurs during the current
                   valuation period, plus or minus

              (c)  a charge or credit for any taxes reserved
                   for, which is determined by IDS Life to
                   have resulted from the investment
                   operations of the subaccount.

         (2)  is the net result of:

              (a)  the asset value per share of the portfolio
                   or the value of a unit of the Trust held in
                   the subaccount determined as of the end of
                   the immediately preceding valuation period,
                   plus or minus

              (b)  the charge or credit for any taxes reserved
                   for in the immediately preceding valuation
                   period.

         (3)  is the percentage factor representing the
              mortality and expense risk charge.  Such factor
              is equal on an annual basis to .90 percent of the
              daily net asset value of the subaccount.  In
              addition, for subaccounts investing in one or
              more Trusts, this factor will include a daily
              asset charge to reimburse IDS Life for the
              transaction charge which it has paid to Shearson
              Lehman.  The transaction charge is currently .25
              percent on an annual basis and is guaranteed to
              never exceed .50 percent.

                   (b)  Furnish a specimen schedule showing
                        the components of the offering price
                        of the trust's securities as at the
                        latest practicable date.

                        No Policy had been offered for sale
                        to the public as of the date of the
                        original registration statement.
<PAGE>
PAGE 65
                   (c)  If there is any variation in the
                        offering price of the trust's
                        securities to any person or classes
                        of persons other than underwriters,
                        state the nature and amount of such 
                        variation and indicate the person or
                        classes of persons to whom such
                        offering is made.

                        There is no variation in offering
                        price of interests in a Subaccount. 
                        The cost of insurance for any given
                        Policy will vary with the age, sex
                        and health of the Insured.

         Policy 3

         Policy value 

         The value of the owner's policy is the sum of values in
         the fixed account and each subaccount of the variable
         account.

         Fixed account value  

         The value in the fixed account on the policy date (when
         the policy is issued) equals the portion of the initial
         net premium that the owner has allocated to the fixed
         account, plus interest accrued before the policy date,
         minus the portion of the monthly deduction for the
         first policy month that the owner has allocated to the
         fixed account.  

         On any later date, the value in the fixed account
         equals:

                 o the value on the previous monthly date; plus
                 o net premiums allocated to the fixed account 
                       since the last monthly date; plus
                 o any transfers to the fixed account from the
                   subaccounts, including loan transfers, since the
                   last monthly date; plus
                 o accrued interest on all of the above; minus
                 o any transfers from the fixed account to the
                   subaccounts, including loan repayment
                   transfers, since the last monthly date;
                   minus
                 o any partial surrenders or partial surrender fees
                   allocated to the fixed account since the
                   last monthly date; minus
                 o interest on any transfers or partial surrenders,
                   from the date of the transfer or surrender to
                   the date of calculation; minus
                 o any portion of the monthly deduction for the
                   coming month that is allocated to the fixed<PAGE>
PAGE 66
                   account if the date of calculation is a monthly
                   date.

         Subaccount values

         The value in each subaccount changes daily, depending
         on the investment performance of the fund portfolio in
         which that subaccount invests and on other factors
         detailed below.  There is no guaranteed minimum
         subaccount value.  The owner bears the entire
         investment risk.
   
         Calculation of subaccount value:  The value in each
         subaccount on the policy date equals the portion of the
         owner's initial net premium allocated to that
         subaccount plus interest accrued before the policy
         date, minus the portion of the monthly deduction for
         the first policy month that you have allocated to that
         subaccount.  The value of each subaccount on each
         valuation date equals:
    
              o the value of the subaccount on the preceding    
                valuation date, multiplied by the net           
                investment factor for the current valuation     
                period (explained below); plus
              o net premiums received and allocated to the      
                subaccount during the current valuation period; 
                plus
              o any transfers to the subaccount (from the fixed 
                account or other subaccounts, including loan    
                repayment transfers) during the period; minus
              o any transfers from the subaccount including     
                loan transfers during the current valuation     
                period; minus 
              o any partial surrenders and partial surrender    
                fees allocated to the subaccount during the     
                period; minus
              o any portion of the monthly deduction allocated  
                to the subaccount during the period.

         The net investment factor measures the investment
         performance of a subaccount from one valuation period
         to the next.  Because performance may fluctuate, the
         value of a subaccount may increase or decrease from day
         to day. 
   
         Accumulation units: The policy value allocated to each
         subaccount is converted into accumulation units.  Each
         time the owner directs a premium payment or transfers
         policy value into one of the subaccounts, a certain
         number of accumulation units are credited to their
         policy for that subaccount.  Conversely, each time they 
         take a partial surrender or transfer value out of a
         subaccount, a certain number of accumulation units are
         subtracted. 
    <PAGE>
PAGE 67
         Accumulation units are the true measure of investment
         value in each subaccount.  For subaccounts investing in
         the fund portfolios, they're related to, but not the
         same as, the net asset value of the corresponding fund
         portfolio.  The dollar value of each accumulation unit
         can rise or fall daily, depending on the investment
         performance of the underlying fund portfolio, and on
         certain charges.  Here's how unit values are
         calculated:

         Number of units: To calculate the number of units for a
         particular subaccount, IDS Life divides the owner's
         investment (net premium or transfer amount) by the
         current accumulation unit value.

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

         Net investment factor: Determined at the end of each
         valuation period, this factor equals (a divided by b) -
         c, where:

              (a) equals:

                   o net asset value per share of the          
                     portfolio; plus

                   o per-share amount of any dividend or       
                     capital gain distribution made by the     
                     relevant fund portfolio to the            
                     subaccount; plus

                   o any credit or minus any charge for        
                     reserves to cover any tax liability       
                     resulting from the investment operations  
                     of the subaccount.

              (b) equals:

                   o net asset value per share of the          
                     portfolio at the end of the preceding     
                     valuation period; plus

                   o any credit or minus any charge for        
                     reserves to cover any tax liability in    
                     the preceding valuation period.

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

         Factors that affect subaccount accumulation units:

         Accumulation units may change in two ways; in number
         and in value.  Here are the factors that influence
         those changes:<PAGE>
PAGE 68
   
         The number of accumulation units the owner owns may
         fluctuate due to:
    
              o additional purchase payments allocated to the   
                subaccounts;
              o transfers into or out of the subaccount(s);
              o partial surrenders and partial surrender fees;
              o surrender charges; and/or
              o monthly deductions

         Accumulation unit values may fluctuate due to:

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

45. Furnish the following information with respect to any
    suspension of the redemption rights of the securities issued
    by the trust during the three fiscal years covered by the
    financial statements filed herewith:

    (a)  by whose action redemption rights were suspended.

    (b)  the number of days notice given to security holders
         prior to suspension of redemption rights.

    (c)  reason for suspension.

    (d)  period during which suspension was in effect.

         Not applicable.

Redemption Valuation of Securities of the Trust

46. (a)  Furnish the following information with respect to the
         method of determining the redemption or withdrawal
         valuation of securities issued by the trust:

         (1)  The source of quotations used to determine the
              value of portfolio securities.

              Net asset values as provided by the Fund's
              Portfolios or value of units of the Trust as
              provided by the Evaluator.

         (2)  Whether opening, closing, bid, asked or any other
              price is used.

              Net asset value or unit value as of the end of
              the appropriate Valuation Period is used.

         (3)  Whether price is as of the day of sale or as of
              any other time.<PAGE>
PAGE 69
              As of the end of the appropriate Valuation
              Period.

         (4)  A brief description of the methods used by
              registrant for determining other assets and
              liabilities including accrual for expenses and
              taxes (including taxes on unrealized
              appreciation).

              See Items 13(d), 17(a) and 18(c).

         (5)  Other items which registrant deducts from the net
              asset value in computing redemption value of its
              securities.

              None, other than as set forth in (4) above.

         (6)  Whether adjustments are made for fractions.
              Not applicable.

    (b)  Furnish a specimen schedule showing the components of
         the redemption price to the holders of the trust's
         securities as at the latest practicable date.

         Not Applicable.

Purchase and Sale of Interests to Underlying Securities from and to
Security Holders

47. Furnish a statement as to the procedure with respect to the
    maintenance of a position in the underlying securities or
    interests in the underlying securities, the extent and nature
    thereof and the person who maintains such a position. 
    Include a description of the procedure with respect to the
    purchase of underlying securities or interests in the
    underlying securities from security holders who exercise
    redemption or withdrawal rights and the sale of such
    underlying securities and interests in the underlying
    securities to other security holders.  State whether the
    method of valuation of such underlying securities and
    interests in the underlying securities differs from that set
    forth in Items 44 and 46.  If any item of expenditure
    included in the determination of the valuation is not or may
    not actually be incurred or expended, explain the nature of
    such item and who may benefit from the transaction.

         Policy 1

         The Subaccounts will maintain positions in Fund shares
         or Trust units by purchasing Fund shares or Trust units
         at net asset value with policy value in accordance with
         instructions from the Owner in the application.  The
         Subaccounts will redeem Fund shares or Trust units at
         net asset value for the purpose of meeting Policy
         obligations, or making adjustments in reserves held in
         the Subaccounts.  There is no procedure for the<PAGE>
PAGE 70
         purchase of underlying securities or interests therein
         from Owners who exercise surrender rights.

         Policy 2 and Policy 3
   
         The Subaccounts will maintain positions in Fund shares
         or Trust units by purchasing Fund shares and/or Trust
         units at net asset value with premiums in accordance
         with instructions from the Owner in the application. 
         The Subaccounts will redeem Fund shares and/or Trust
         units at net asset value for the purpose of meeting
         Policy obligations or making adjustments in reserves
         held in the Subaccounts.  There is no procedure for the
         purchase of underlying securities or interest therein
         from Owners who exercise surrender rights.
    
                          V.

INFORMATION CONCERNING THE TRUSTEE OR CUSTODIAN

48. Furnish the following information as to each trustee or
    custodian of the trust.

    (a)  Name and principal business address:

         Not applicable as IDS Life will serve as custodian for
         the Variable Account.

    (b)  Form of organization.

         Not applicable as IDS Life will serve as custodian for
         the Variable Account.

    (c)  State or other sovereign power under the laws of which
         the trustee or custodian was organized.

         Not applicable as IDS Life will serve as custodian for
         the Variable Account.

    (d)  Name of governmental supervising or examining
         authority.

         Not applicable as IDS Life will serve as custodian for
         the Variable Account.

49. State the basis for payment of fees or expenses of the
    trustee or custodian for services rendered with respect to
    the trust and its securities, and the aggregate amount
    thereof for the last fiscal year.  Indicate the person paying
    such fees or expenses.  If any fees or expenses are prepaid,
    state the unearned amounts.

    See Item 48.

50. State whether the trustee or custodian or any other person
    has or may create a lien on the assets of the trust and, if
    so, give full particulars, outlining the substance of the<PAGE>
PAGE 71
    provisions of any indenture or agreement with respect
    thereto.

    Not applicable.

                          VI.

INFORMATION CONCERNING INSURANCE OF HOLDERS OF SECURITIES

51. Furnish the following information with respect to the
    insurance of holders of securities:

    (a)  The name and address of the insurance company.

         All insurance elements of the Policy are provided by
         IDS Life.

    (b)  The types of policies and whether individual or group
         policies.

         Policy 1

         The Policy is a single premium variable life insurance
         policy and is issued on an individual basis.

         Policy 2

         The Policy is a flexible premium variable life
         insurance policy and is issued on an individual basis.

         Policy 3

         The policy is a flexible premium survivorship variable
         life insurance policy and is issued on an individual
         basis.

    (c)  The types of risks insured and excluded.
   
         Under the Policies the Company assumes the risk that
         insureds covered by the Policies may die before
         anticipated and that the charge for this mortality risk
         may prove insufficient.  The Company assumes an expense
         risk that deductions for expenses may not be adequate. 
         Under Policy 1, the Company assumes the risk in
         guaranteeing that the death benefit will not fall below
         the initial death benefit, regardless of the investment
         performance of the Fund Portfolios or valuation of
         units of the Trust.  Under Policy 2, the company
         assumes the risks under the death benefits guarantee if
         the minimum monthly premiums are timely paid.  Under
         Policy 3, the company assumes the risks under the death
         benefit guarantees if the minimum initial premium
         and/or the death benefit guarantee premiums are timely
         paid.
    <PAGE>
PAGE 72
    (d)  The coverage of the policies.

         See Paragraph (c) of this Item.

    (e)  The beneficiaries of such policies and the uses to
         which the proceeds of policies must be put.

         The recipient of the benefits of the insurance
         undertakings described in Item 51(c) is either the
         designated primary beneficiary, any contingent
         beneficiaries, or the estate of the insured as stated
         in the application for the Policy.  There is no
         limitation on the use of the proceeds.

    (f)  The terms and manner of cancellation and of
         reinstatement.

         The insurance undertakings described in Item 51(c) are
         integral parts of the Policy and may not be canceled
         while the Policy remains in effect.  See Item 10(d)
         with respect to lapse of the Policy.

    (g)  The method of determining the amount of premiums to be
         paid by holders of securities.

         Policy 1

         The Owner may choose to purchase a policy based upon
         the single premium which the Owner wishes to pay, or on
         the initial death benefit which the Owner desires to
         purchase.  The amount of the initial death benefit
         depends upon the Single Premium and the insured's age
         and sex.  The minimum Single Premium which can be
         purchased is $5,000 and the maximum is $500,000.

         Policy 2

         The amount and frequency of premium payments will
         affect the policy value, the Cash Surrender Value, and
         how long the Policy will remain in force (including
         affecting whether the Death Benefit Guarantee is in
         effect).  After the initial premium, the Owner may
         determine the amount and timing of subsequent premium
         payments, subject to certain limitations.  In most
         cases, payment of cumulative premiums sufficient to
         maintain the Death Benefit Guarantee will be required
         to keep the Policy in force during at least the first
         several policy years.

         The initial premium is the amount of money submitted by
         the Owner with the application.  It is the combination
         of the Scheduled Premium and any unscheduled premium.
         The scheduled premium is the premium shown on the
         Policy Data page of the Policy.  The scheduled premium
         will serve only as an indication of the Owner's intent
         as to the frequency and amount of future premium
         payments.<PAGE>
PAGE 73
         The Owner may change the amount and frequency of
         scheduled premium payments by written request.  The
         Owner may also skip scheduled premium payments.  Any
         change in amount may be subject to applicable tax laws
         and regulations.

         Scheduled premiums may be paid annually, semi-annually,
         or quarterly.  Payment at any other interval must be
         approved by IDS Life.  The minimum scheduled premium
         payment IDS Life will accept is $25.  IDS Life also
         reserves the right to limit the amount of any increase
         in scheduled premiums.

         An unscheduled premium is any premium paid that is not
         included with a Scheduled Premium.  There is no
         maximum.  However, the Company reserves the right to
         limit the number and amount of unscheduled premiums.

         In order to receive favorable tax treatment under
         sections 72, 101 and 7702 of the Internal Revenue Code,
         the premiums paid during the life of the Policy must
         not exceed certain premium guideline limitations.  In
         order to comply with the law, IDS Life can either
         refuse excess premiums as they are paid, or refund
         premiums with interest no later than 60 days after the
         Policy Anniversary in which they were paid.

         Until the insured's attained age 70, or five years from
         the policy date, whichever is later, the policy will
         not terminate even if the cash surrender value is
         insufficient to cover the monthly deduction on a
         monthly date if (a) equals or exceeds (b) where:

         (a)  is the sum of all premiums paid, minus any
              partial surrenders, and minus any indebtedness;
              and

         (b)  is the minimum monthly premium, as shown under
              Policy Date in the Policy, times the number of
              months since the Policy Date, including the
              current month.

         Minimum monthly premiums may be paid on other than a
         monthly basis as long as the sum of premiums paid is at
         least equal to the total required Minimum Monthly
         Premiums at all times. 

         If on a monthly date, sufficient premiums have not been
         paid to maintain the Death Benefit Guarantee, an
         additional period of 61 days will be allowed for the
         payment of a premium sufficient to pay the required
         minimum monthly premiums.  Notice of such premium will
         be mailed to the Owner's last known address.  If the
         premium is not paid within this period, the death
         benefit guarantee provision will no longer be in effect
         and cannot be reinstated.
<PAGE>
PAGE 74
         The minimum monthly premium will change if the
         specified amount is increased or decreased or if riders
         are added, changed or terminated.  The new minimum
         monthly premium will apply from the date of the change.

         A death benefit guarantee charge is included in the
monthly deduction in the first five policy years or
until the insured's attained age 70, whichever is
later.  The charge will not be taken if, as described
         above, the death benefit guarantee provision is no
         longer in effect.

         For any month that the monthly deduction is being paid
         for by a Waiver of Monthly Deduction Rider attached to
         the policy, the minimum monthly premium for that month
         will be zero.

         Policy 3

         Payment of premiums:

         In applying for the policy, the owner decides how much
         they intend to pay and how often they will make
         payments.  During the early policy years until the
         policy value is sufficient to cover the surrender
         charge, IDS Life requires that the owner pay the
         premiums sufficient to keep the DBG-85 in effect.

         The owner may schedule payments annually, semiannually,
         or quarterly.  (Payment at any other interval must be
         approved by IDS Life.)  This premium schedule is shown
         in the owner's policy.

         The scheduled premium serves only as an indication of
         the owner's intent as to the frequency and amount of
         future premium payments.  The owner may skip scheduled
         premium payments at any time if the cash surrender
         value is sufficient to pay the monthly deduction, or if
         the owner has paid sufficient premium to keep the DBG-
         85 or the DBG-100 in effect.

         The owner may also change the amount and frequency of
         scheduled premium payments by written request.  IDS
         Life reserves the right to limit the amount of such
         changes.  Any change in the premium amount is subject
         to applicable tax laws and regulations. 

         Although the owner has flexibility in paying premiums,
         the amount and frequency of the owner's payments will
         affect the policy value, cash surrender value and
         length of time their policy will remain in force, as
         well as affect whether the DBG-85 or DBG-100 remain in
         effect.
<PAGE>
PAGE 75
         Premium limitations:

         The owner may make unscheduled premium payments at any
         time and in an amount of at least $50.  IDS Life
         reserves the right to limit the number and amount of
         unscheduled premium payments.

         No premium payments, scheduled or unscheduled, are
         allowed on or after the youngest insured's attained
         insurance age 100.

         Also, in order to receive favorable tax treatment under
         the Code, premiums paid during the life of the policy
         must not exceed certain limitations.  To comply with
         the Code, IDS Life can either refuse excess premiums as
         they are paid, or refund excess premiums with interest
         no later than 60 days after the end of the policy year
         in which they were paid.

         Keeping the policy in force  
   
         This section includes a description of the policy
         provisions that determines if the policy will remain in
         force or lapse (terminate).  It is important that the
         owner understands them so the appropriate premium
         payments are made to ensure that insurance coverage
         meets the owner's objectives.
    
         If the owner wishes to have a guarantee that the policy
         will remain in force until the youngest insured's
         attained insurance age 100 regardless of investment
         performance, they should pay at least the DBG-100
         premiums.

         If they wish to pay a lower premium and are satisfied
         to have a guarantee that the policy will remain in
         force until the youngest insured's attained insurance
         age 85 (or 15 policy years, if later) regardless of
         investment performance, they should pay at least the
         DBG-85 premiums.
   
         If they wish to pay yet a lower premium and are not
         concerned with a long-term guarantee that the policy
         will remain in force regardless of investment
         performance, they can pay premiums so that the cash
         surrender value on each monthly date is sufficient to
         pay the monthly deduction.  However, during the minimum
         initial premium period, they must pay at least the
         minimum initial premium until the policy value is
         greater than the surrender charge and the cash
         surrender value is sufficient to pay the monthly
         deduction.  At that time the owner may be able to
         reduce their premiums as long as the cash surrender
         value continues to be sufficient to pay the monthly
         deduction.
    <PAGE>
PAGE 76
         Death benefit guarantee to age 85

         The DBG-85 provides that the policy will remain in
         force until the youngest insured reaches attained
         insurance age 85 (or 15 policy years, if later) even if
         the cash surrender value is insufficient to pay the
         monthly deduction.  The DBG-85 will remain in effect,
         as long as:

              the sum of premiums paid - partial surrenders -
              outstanding indebtedness

              equals or exceeds

              the DBG-85 premiums due since the policy date.

         The DBG-85 premium is shown in the policy.
   
         If, on a monthly date, the owner has not paid enough
         premiums to keep the DBG-85 in effect, an additional
         period of 61 days will be allowed for the owner to pay
         a premium sufficient to bring the total up to the
         required minimum.  If they do not pay this amount
         within 61 days, the DBG-85 will terminate.  The owner's
         policy will also lapse (terminate) if the cash
         surrender value is less than the amount needed to pay
         the monthly deduction and the minimum initial premium
         is not in effect.  Although the policy can be
         reinstated as explained below, the DBG-85 cannot be
         reinstated.
    
         Death benefit guarantee to age 100

         The DBG-100 provides that the policy will remain in
         force until the youngest insured's attained insurance
         age 100 even if the cash surrender value is
         insufficient to pay the monthly deduction.  The DBG-100
         will remain in effect, as long as: 

              the sum of premiums paid - partial surrenders -
              outstanding  indebtedness

              equals or exceeds

              the DBG-100 premiums due since the policy date.

         The DBG-100 premium is shown in the policy.
   
         If, on a monthly date, the owner has not paid enough
         premiums to keep the DBG-100 in effect, an additional
         period of 61 days will be allowed for the owner to pay
         a premium sufficient to bring the total up to the
         required minimum.  If they do not pay this amount
         within 61 days, the DBG-100 will terminate.  If they
         have paid sufficient premium, the DBG-85 will be in
         effect.  If the DBG-85 and DBG-100 are not in effect,
         their policy will lapse (terminate) if the cash<PAGE>
PAGE 77
         surrender value is less than the amount needed to pay
         the monthly deduction and the minimum initial premium
         period is not in effect.  Although the policy can be
         reinstated as explained below, the DBG-100 cannot be
         reinstated.
       
         Minimum initial premium period

         To allow the owner the opportunity to increase their
         policy value gradually so that the cash surrender value
         is sufficient to pay the monthly deduction, they may
         choose to pay only the minimum initial premium during
         the minimum initial premium period as long as the
         policy value minus indebtedness equals or exceeds the
         monthly deduction.  The policy will not enter the grace
         period during the minimum initial premium period as
         shown under Policy Date, if:

         1.  on a monthly date, the policy value minus
         indebtedness equals or exceeds the monthly deduction
         for the policy month following such monthly date; and

         2.  the sum of all premiums paid, minus any partial
         surrenders, and minus any indebtedness equals or
         exceeds the minimum initial premium, as shown under
         Policy Date, times the number of months since the
         Policy Date, including the current month.

         The minimum initial period is

         4 years if the youngest insured's insurance age is
         20-29
         3 years if the youngest insured's insurance age is 
         30-39
         2 years if the youngest insured's insurance age is 
         40-49
         1 year if the youngest insured's insurance age is 50
         and over

         Grace period

         If the cash surrender value of the policy becomes less
         than that needed to pay the monthly deduction and
         neither of the death benefit guarantees nor the minimum
         initial premium period is in effect, the owner will
         have 61 days to pay the required premium amount.  If
         the required premium is not paid, the policy will
         lapse.

         IDS Life will mail a notice to the owner's last known
         address, requesting payment of the premium needed so
         that the next three monthly deductions can be made.  If
         IDS Life receives this premium before the end of the
         61-day grace period, IDS Life will use the payment to
         pay all monthly deductions and any other charges then
         due.  Any balance will be added to the policy value and
         allocated in the same manner as other premium payments.<PAGE>
PAGE 78 
         If a policy lapses with outstanding indebtedness, any
         excess of the outstanding indebtedness over the premium
         paid generally will be taxable to the owner.  If the
         last surviving insured dies during the grace period,
         any overdue monthly deductions will be deducted from
         the death benefit.
    
    (h)  The amount of aggregate premiums paid to the insurance
         company during the fiscal year.

         Not applicable.

    (i)  Whether any person other than the insurance company
         receives any part of such premiums, the name of each
         such person and the amount involved, and the nature of
         the services rendered therefor.
       
         No person other than IDS Life receives any part of the
         premiums or the amounts deducted for the mortality and
         expense risk charge or other applicable charges.  IDS
         Life may, from time to time, enter into reinsurance
         treaties with other insurers whereby these insurers may
         agree to reimburse IDS Life for mortality expenses. 
         However, any such arrangements do not affect the
         Policy.
       
    (j)  The substance of any other material provisions of any
         indenture or agreement of the trust relating to
         insurance.

         Not applicable.

VII.

POLICY OF REGISTRANT

52. (a)  Furnish the substance of the provisions of any
         indenture or agreement with respect to the conditions
         upon which and the method of selection by which
         particular portfolio securities must or may be
         eliminated from the assets of the trust or must or may
         be replaced by other portfolio securities.  If an
         investment adviser or other person is to be employed in
         connection with such selection, elimination or
         substitution, state the name of such person, the nature
         of any affiliation to the depositor, trustee or
         custodian, and any principal underwriter, and the
         amount of remuneration to be received for such
         services.  If any particular person is not designated
         in the indenture or agreement, describe briefly the
         method of selection of such person.
   
         If shares of any Fund Portfolio and/or units of the
         Trust should not be available for purchase by the
         appropriate Subaccount or if, in the judgment of IDS
         Life's management, further investment in such shares is
         no longer appropriate in view of the purposes of the<PAGE>
PAGE 79
         Subaccount, shares of another registered, open-end
         management investment company and/or units of another
         unit investment trust may be substituted for Fund
         shares and/or Trust units, respectively, held, in the
         subaccount.  If deemed by IDS Life to be the best
         interest of persons having voting rights under the
         subaccount may be operated as a management company
         under the Investment Company Act of 1940 or it may be
         deregistered under such Act in the event such
         registration is no longer required.  In the event of
         any such substitution or change, IDS Life may, without
         the consent or approval of the Owners, amend the Policy
         and take whatever action is necessary and appropriate. 
         However, no such substitution or change will be made
         without any necessary approval of the Securities and
         Exchange Commission.
    
    (b)  Furnish Information with respect to each transaction
         involving the elimination of any underlying security
         during the period covered by the financial statements
         filed herewith.

         Not applicable.

    (c)  Describe the policy of the trust with respect to the
         substitution and elimination of the underlying
         securities of the trust with respect to:

         (1)  the grounds for elimination and substitution;

         (2)  the type of securities which may be substituted
              for any underlying security;

         (3)  whether the acquisition of such substituted
              security or securities would constitute the
              concentration of investment in a particular
              industry or group of industries or would conform
              to a policy of concentration of investment in a
              particular industry or group of industries;

         (4)  whether such substituted securities may be the
              securities of any other investment company; and

         (5)  the substance of the provisions of any indenture
              or agreement which authorize or restrict the
              policy of the registrant in this regard.

              See Item 52(a).

    (d)  Furnish a description of any policy (exclusive of
         policies covered by Paragraphs (a) and (b) herein) of
         the trust which is deemed a matter of fundamental
         policy and which is elected to be treated as such.

         None.
<PAGE>
PAGE 80
Regulated Investment Company

53. (a)  State the taxable status of the trust.
   
         The Policies are designed for use by individuals in
         meeting their insurance and financial security needs. 
         The ultimate effect of the Federal income taxes on the
         Policy Value, on benefit payments and on the economic
         benefit to the Policy Owner or Beneficiary depends on
         both IDS Life's tax status and upon the tax status of
         the individual concerned.
       
         IDS Life is taxed as a life insurance company under the
         Code.  Since the variable Account is not a separate
         entity from IDS Life for tax purposes, and its
         operations form a part of IDS Life, it will not be
         taxed separately as a "regulated investment company"
         under Subchapter M of the Code.
    
    (b)  State whether the trust qualified for the last taxable
         year as a regulated investment company as defined in
         Section 851 of the Internal Revenue Code of 1954, and 
         state its present intention with respect to such
         qualification during the current taxable year.

         Not applicable.

VIII.

FINANCIAL AND STATISTICAL INFORMATION

54. If the trust is not the issuer of periodic payment plan
    certificates, furnish the following information with respect
    to each class or series of its securities.

    Not applicable.

55. If the trust is the issuer of periodic payment plan
    certificates, a transcript of a hypothetical account shall be
    filed in approximately the following form on the basis of the
    certificate calling for the smallest amount of payments.  The
    schedule shall cover a certificate of the type currently
    being sold assuming that such certificate had been sold at a
    date approximately ten years prior to the date of
    registration or at the approximate date of organization of
    the trust.

         Policy 2
   
         Policy illustrations

         The following tables illustrate how policy values, cash
         surrender values and death benefits may change with the
         investment experience of the subaccount.  The tables
         show how these amounts might vary, for a 35-year-old
         male nonsmoker, under Death Benefit Option 1, if:
<PAGE>
PAGE 81
         o  the annual rate of return is 0%, 6% or 12%. 

         o  cost of insurance rates and policy fees are--current
         rates and fees for policies purchased on or after May
         1, 1993 (October 1, 1993 for New Jersey)--current rates
         and fees for policies purchased before May 1, 1993
         (October 1, 1993 for New Jersey)--guaranteed rates and
         fees.

         Any such illustration involves a number of detailed
         assumptions (see "Understanding the illustrations"). 
         To the extent that your own circumstances differ from
         those assumed in the illustrations, your expected
         results would also differ.

         Upon request, you will be furnished with comparable
         tables illustrating death benefits, policy values, and
         cash surrender values based on the actual age of the
         person you propose to insure and on an initial
         specified amount and premium payment schedule.  In
         addition, after you have purchased a policy, you may
         request illustrations based on policy values at the
         time of request.
    
         Understanding the illustrations:

         Rates of return: assumed to be uniform, gross,
         after-tax, annual rates of 0%, 6%, or 12% for the fund. 
         Results would differ depending on allocations among the
         subaccounts, if returns averaged 0%, 6% and 12% for the
         fund as a whole but differed across portfolios.

         Insured: assumed to be a male insurance age 35, in a
         standard rate classification, qualifying for the
         nonsmoker rate.  Results would be lower if the insured
         were in a substandard rate classification or did not
         qualify for the non-smoker rate.   

         Premiums: A $900 premium is assumed to be paid in full
         at the beginning of each policy year.  Results would
         differ if premiums were paid on a different schedule.

         Policy loans and partial withdrawals: It is assumed
         that none have been made.  (Since indebtedness is
         assumed to be zero, the cash surrender value in all
         cases equals the policy value minus the surrender
         charge.)

         Effect of expenses and charges: The net investment
         return of the subaccounts, shown in the tables, is
         lower than the gross, after-tax return of the fund
         because expenses paid by the fund and charges made
         against the subaccounts have been deducted.  These
         include:   
<PAGE>
PAGE 82
         o    the daily investment management fee paid by the
              fund, assumed to be equivalent to an annual rate
              of 0.6% of the fund's aggregate average daily net
              assets;
         o    the daily mortality and expense risk charge,
              equivalent to 0.9% of the daily net asset value
              of the subaccounts annually; and
         o    an annual charge of 0.1% of the fund's aggregate
              average daily net assets for direct expenses
              incurred by the fund.

         The latter charge is capped by IDS Life at 0.1%, even
         though actual expenses have been higher, ranging from
         0.6% to 0.8% of the average daily net assets of the
         different portfolios in the year ended April 30, 1993. 
         Although IDS Life reserves the right to discontinue
         capping these expenses, our present intent is to
         continue the cap indefinitely until actual expenses are
         less than the cap.  Should IDS Life discontinue the cap
         prior to that time, the policy values and death
         benefits in the tables generally would be less. 

         After deduction of the above expenses and charges, the
         illustrated gross annual investment rates of return of
         0%, 6%, and 12% correspond to approximate net annual
         rates of -1.59%, 4.32%, and 10.22%, respectively. 

         Taxes: Results shown in the tables reflect the fact
         that IDS Life does not currently charge the subaccounts
         for federal income tax.  If such a charge is taken in
         the future, the portfolios will have to earn more than
         they do now in order to produce the death benefits and
         policy values illustrated.
<PAGE>
PAGE 83
<TABLE><CAPTION>
Illustration                                                                      Policies purchased on or after May 1, 1993
_____________________________________________________________________________________________________________________________
Initial specified amount $100,000                      Male age 35                                 Current costs assumed
Death benefit Option 1                                 nonsmoker                                    annual premium $900
_____________________________________________________________________________________________________________________________
           Premium          Death benefit (1)(2)               Policy value (1)(2)               Cash surrender value (1)(2)
           accumulated      assuming hypothetical gross        assuming hypothetical gross       assuming hypothetical gross
End of     with annual      annual investment return of        annual investment return of       annual investment return Of
policy     interest
year       at 5%          0%           6%          12%         0%        6%        12%          0%        6%        12%
_____________________________________________________________________________________________________________________________
    <S>    <C>        <C>          <C>          <C>         <C>       <C>        <C>          <C>       <C>        <C>
     1     $  945     $100,000     $100,000     $100,000    $  605    $  648     $  691       $   0     $   1      $  44
     2      1,937      100,000      100,000      100,000     1,202     1,326      1,455         475       598        727
     3      2,979      100,000      100,000      100,000     1,779     2,022      2,285         993     1,236      1,499
     4      4,073      100,000      100,000      100,000     2,336     2,737      3,190       1,491     1,893      2,346
     5      5,222      100,000      100,000      100,000     2,873     3,473      4,177       1,972     2,572      3,276

     6      6,428      100,000      100,000      100,000     3,392     4,230      5,255       2,671     3,509      4,534
     7      7,694      100,000      100,000      100,000     3,892     5,010      6,434       3,352     4,470      5,894
     8      9,024      100,000      100,000      100,000     4,371     5,812      7,722       4,011     5,451      7,362
     9     10,420      100,000      100,000      100,000     4,827     6,632      9,128       4,647     6,452      8,948
    10     11,886      100,000      100,000      100,000     5,257     7,471     10,662       5,257     7,471     10,662

    11     13,425      100,000      100,000      100,000     5,663     8,329     12,338       5,663     8,329     12,338
    12     15,042      100,000      100,000      100,000     6,043     9,207     14,172       6,043     9,207     14,172
    13     16,739      100,000      100,000      100,000     6,396    10,104     16,178       6,396    10,104     16,178
    14     18,521      100,000      100,000      100,000     6,720    11,018     18,375       6,720    11,018     18,375
    15     20,392      100,000      100,000      100,000     7,013    11,948     20,779       7,013    11,948     20,779

    16     22,356      100,000      100,000      100,000     7,272    12,894     23,413       7,272    12,894     23,413
    17     24,419      100,000      100,000      100,000     7,495    13,852     26,301       7,495    13,852     26,301
    18     26,585      100,000      100,000      100,000     7,678    14,820     29,467       7,678    14,820     29,467
    19     28,859      100,000      100,000      100,000     7,815    15,794     32,940       7,815    15,794     32,940
    20     31,247      100,000      100,000      100,000     7,901    16,770     36,753       7,901    16,770     36,753

age 60     45,102      100,000      100,000      100,000     7,405    21,540     62,448       7,405    21,540     62,448
age 65     62,785      100,000      100,000      127,948     4,791    25,684    104,875       4,791    25,684    104,875

(1) Assumes no policy loans or partial withdrawals have been made.

(2) Assumes a $900 premium is paid at the beginning of each policy year.  Values will be different if premiums are paid in
    different amounts or with a different frequency.

The above hypothetical investment results are illustrative only and should not be deemed a representation of past or future
investment results.  Actual investment results may be more or less than those shown.  The death benefit, policy value and cash
surrender value would be different from those shown if returns averaged 0%, 6%, and 12% over a period of years, but fluctuated
above and below those averages for individual policy years.  No representation can be made that these  hypothetical rates of return
can be achieved for any one year or sustained over any period of time.
<PAGE>
PAGE 84
Illustration                                                                          Policies purchased before May 1, 1993
_____________________________________________________________________________________________________________________________
Initial specified amount $100,000                      Male age 35                                 Current costs assumed
Death benefit Option 1                                 nonsmoker                                    annual premium $900
_____________________________________________________________________________________________________________________________
           Premium          Death benefit (1)(2)               Policy value (1)(2)               Cash surrender value (1)(2)
           accumulated      assuming hypothetical gross        assuming hypothetical gross       assuming hypothetical gross
End of     with annual      annual investment return of        annual investment return of       annual investment return of
policy     interest
year       at 5%          0%          6%         12%         0%          6%         12%          0%           6%        12%
_____________________________________________________________________________________________________________________________
     1     $  945     $100,000    $100,000    $100,000    $  605      $  648      $  691      $    0       $    1     $   44
     2      1,937      100,000     100,000     100,000     1,202       1,326       1,455         475          598        727
     3      2,979      100,000     100,000     100,000     1,779       2,022       2,285         993        1,236      1,499
     4      4,073      100,000     100,000     100,000     2,336       2,737       3,190       1,491        1,893      2,346
     5      5,222      100,000     100,000     100,000     2,873       3,473       4,177       1,972        2,572      3,276

     6      6,428      100,000     100,000     100,000     3,380       4,218       5,243       2,660        3,498      4,522
     7      7,694      100,000     100,000     100,000     3,869       4,986       6,409       3,329        4,446      5,868
     8      9,024      100,000     100,000     100,000     4,329       5,766       7,674       3,969        5,406      7,314
     9     10,420      100,000     100,000     100,000     4,772       6,571       9,061       4,591        6,391      8,880
    10     11,886      100,000     100,000     100,000     5,186       7,390      10,570       5,186        7,390     10,570
 
    11     13,425      100,000     100,000     100,000     5,572       8,224      12,217       5,572        8,224     12,217
    12     15,042      100,000     100,000     100,000     5,931       9,075      14,016       5,931        9,075     14,016
    13     16,739      100,000     100,000     100,000     6,253       9,932      15,974       6,253        9,932     15,974
    14     18,521      100,000     100,000     100,000     6,548      10,809      18,120       6,548       10,809     18,120
    15     20,392      100,000     100,000     100,000     6,807      11,694      20,464       6,807       11,694     20,464

    16     22,356      100,000     100,000     100,000     7,030      12,589      23,030       7,030       12,589     23,030
    17     24,419      100,000     100,000     100,000     7,207      13,486      25,834       7,207       13,486     25,834
    18     26,585      100,000     100,000     100,000     7,337      14,384      28,904       7,337       14,384     28,904
    19     28,859      100,000     100,000     100,000     7,412      15,274      32,264       7,412       15,274     32,264
    20     31,247      100,000     100,000     100,000     7,420      16,146      35,942       7,420       16,146     35,942

age 60     45,102      100,000     100,000     100,000     6,601      20,390      60,812       6,601       20,390     60,812
age 65     62,785      100,000     100,000     124,315     3,230      23,445     101,900       3,230       23,445    101,900

(1)  Assumes no policy loans or partial withdrawals have been made.

(2)  Assumes a $900 premium is paid at the beginning of each policy year.  Values will be different if premiums are paid in
     different amounts or with a different frequency.

The above hypothetical investment results are illustrative only and should not be deemed a representation of past or future
investment results.  Actual investment results may be more or less than those shown.  The death benefit, policy value and cash
surrender value would be different from those shown if returns averaged 0%, 6%, and 12% over a period of years, but fluctuated
above and below those averages for individual policy years.  No representation can be made that these  hypothetical rates of return
can be achieved for any one year or sustained over any period of time.
<PAGE>
PAGE 85
Illustration
_____________________________________________________________________________________________________________________________
Initial specified amount $100,000                      Male age 35                              Guaranteed costs assumed
Death benefit Option 1                                 nonsmoker                                    annual premium $900
_____________________________________________________________________________________________________________________________
           Premium          Death benefit (1)(2)               Policy value (1)(2)               Cash surrender value (1)(2)
           accumulated      assuming hypothetical gross        assuming hypothetical gross       assuming hypothetical gross
End of     with annual      annual investment return of        annual investment return of       annual investment return of
policy     interest
year       at 5%          0%          6%         12%          0%         6%        12%           0%          6%         12%
_____________________________________________________________________________________________________________________________
     1     $  945     $100,000    $100,000    $100,000     $  605     $  648     $  660       $    0      $    1      $   12
     2      1,937      100,000     100,000     100,000      1,172      1,295      1,388          445         568         661
     3      2,979      100,000     100,000     100,000      1,720      1,959      2,180          934       1,173       1,394
     4      4,073      100,000     100,000     100,000      2,248      2,640      3,042        1,403       1,796       2,198
     5      5,222      100,000     100,000     100,000      2,757      3,341      3,982        1,856       2,440       3,081

     6      6,428      100,000     100,000     100,000      3,236      4,050      4,996        2,515       3,329       4,275
     7      7,694      100,000     100,000     100,000      3,697      4,780      6,104        3,156       4,239       5,564
     8      9,024      100,000     100,000     100,000      4,129      5,520      7,306        3,769       5,159       6,945
     9     10,420      100,000     100,000     100,000      4,544      6,282      8,622        4,364       6,102       8,441
    10     11,886      100,000     100,000     100,000      4,932      7,057     10,053        4,932       7,057      10,053

    11     13,425      100,000     100,000     100,000      5,291      7,845     11,614        5,291       7,845      11,614
    12     15,042      100,000     100,000     100,000      5,624      8,647     13,317        5,624       8,647      13,317
    13     16,739      100,000     100,000     100,000      5,920      9,454     15,169        5,920       9,454      15,169
    14     18,521      100,000     100,000     100,000      6,189     10,276     17,197        6,189      10,276      17,197
    15     20,392      100,000     100,000     100,000      6,422     11,105     19,411        6,422      11,105      19,411

    16     22,356      100,000     100,000     100,000      6,609     11,931     21,822        6,609      11,931      21,822
    17     24,419      100,000     100,000     100,000      6,760     12,764     24,463        6,760      12,764      24,463
    18     26,585      100,000     100,000     100,000      6,866     13,596     27,353        6,866      13,596      27,353
    19     28,859      100,000     100,000     100,000      6,915     14,416     30,512        6,915      14,416      30,512
    20     31,247      100,000     100,000     100,000      6,898     15,215     33,965        6,898      15,215      33,965

age 60     45,102      100,000     100,000     100,000      5,674     18,740     57,045        5,674      18,740      57,045
age 65     62,785      100,000     100,000     116,888      1,599     20,552     95,188        1,599      20,552      95,188

(1)  Assumes no policy loans or partial withdrawals have been made.

(2)  Assumes a $900 premium is paid at the beginning of each policy year.  Values will be different if premiums are paid in
     different amounts or with a different frequency.

The above hypothetical investment results are illustrative only and should not be deemed a representation of past or future
investment results.  Actual investment results may be more or less than those shown.  The death benefit, policy value and cash
surrender value would be different from those shown if returns averaged 0%, 6%, and 12% over a period of years, but fluctuated
above and below those averages for individual policy years.  No representation can be made that these  hypothetical rates of return
can be achieved for any one year or sustained over any period of time.
</TABLE>

Policy 3

Policy illustrations 

The following tables illustrate how policy values, cash surrender
values and death benefits may change with the investment experience
of the subaccount.  The tables show how these amounts might vary,
for a male insurance age 55 and a female insurance age 55, both
nonsmokers, if:

     o the annual rate of return of the fund is 0%, 6% or 12%. 
     o the cost of insurance rates are current rates or guaranteed
      rates.

Any such illustration involves a number of detailed assumptions
(see "Understanding the illustrations").  To the extent that your
own circumstances differ from those assumed in the illustrations,
your expected results would also differ. 
<PAGE>
PAGE 86
Upon request, you will be furnished with comparable tables
illustrating death benefits, policy values, and cash surrender
values based on the actual ages of the persons you propose to
insure and on an initial specified amount and premium payment
schedule.  In addition, after you have purchased a policy, you may
request illustrations based on policy values at the time of
request.
   
Understanding the illustrations:

Rates of return: assumed to be uniform, gross, after-tax, annual
rates of 0%, 6%, or 12% for the fund.  Results would differ
depending on allocations among the subaccounts, if returns averaged
0%, 6% and 12% for the fund as a whole but differed across
portfolios.

Insureds: assumed to be a male insurance age 55 and a female
insurance age 55, in a standard risk classification, qualifying for
the nonsmoker rate.  Results would be lower if one or both of the
insureds were in a substandard risk classification or did not
qualify for the non-smoker rate.   

Premiums: A $15,000 premium is assumed to be paid in full at the
beginning of each policy year.  Results would differ if premiums
were paid on a different schedule.

Policy loans and partial withdrawals: It is assumed that none have
been made.  (Since indebtedness is assumed to be zero, the cash
surrender value in all cases equals the policy value minus the
surrender charge.)

Effect of expenses and charges: The net investment return of the
subaccounts, shown in the tables, is lower than the gross,
after-tax return of the fund because expenses paid by the fund and
charges made against the subaccounts have been deducted.  These
include:   

o the daily investment management fee paid by the fund, assumed to
  be equivalent to an annual rate of 0.7% of the fund's aggregate
  average daily net assets;
o the daily mortality and expense risk charge, equivalent to 0.9%
  of the daily net asset value of the subaccounts annually; and 
o an annual charge of 0.1% of the fund's aggregate average daily
  net assets for direct expenses incurred by the fund.

The latter charge is capped by IDS Life at 0.1%, even though actual
expenses have been higher, ranging from 0.6% to 0.8% of the average
daily net assets of the different portfolios in the year ended
April 30, 1994.  Although IDS Life reserves the right to
discontinue capping these expenses, our present intent is to
continue the cap indefinitely until actual expenses are less than 
the cap.  Should IDS Life discontinue the cap prior to that time,
the policy values and death benefits in the tables generally would
be less.

(After deduction of the above expenses and charges, the illustrated
gross annual investment rates of return of 0%, 6%, and 12%<PAGE>
PAGE 87
correspond to approximate net annual rates of -1.69%, 4.21%, and
10.11%, respectively.)

Taxes:  Results shown in the tables reflect the fact that IDS Life
does not currently charge the subaccounts for federal income tax. 
If such a charge is taken in the future, the portfolios will have
to earn more than they do now in order to produce the death
benefits and policy values illustrated.
<TABLE><CAPTION>
Illustration                                                                                                                
                                                                                                                             
Initial specified amount $1,000,000            Male -   Insurance age 55 - Nonsmoker               Current costs assumed
Death benefit Option 1                         Female - Insurance age 55 - Nonsmoker                annual premium $15,000   
           Premium          Death benefit (1)(2)               Policy value (1)(2)               Cash surrender value (1)(2)
           accumulated      assuming hypothetical gross        assuming hypothetical gross       assuming hypothetical gross
End of     with annual      annual investment return of        annual investment return of       annual investment return Of
policy     interest
year       at 5%          0%           6%          12%         0%        6%        12%          0%        6%        12%      
    <S>     <C>           <C>          <C>         <C>          <C>       <C>        <C>         <C>       <C>        <C> 
     1      15750         1000000      1000000     1000000      12651     13424      14196        8651      9424      10196
     2      32288         1000000      1000000     1000000      25091     27415      29830       21091     23415      25830       
     3      49652         1000000      1000000     1000000      37208     41880      46926       33208     37880      42926
     4      67884         1000000      1000000     1000000      48899     56727      65520       44899     52727      61520
     5      87029         1000000      1000000     1000000      60287     72093      85888       56287     68093      81888

     6     107130         1000000      1000000     1000000      71159     87781     107990       67559     84181     104390
     7     128237         1000000      1000000     1000000      81642    103927     132130       78442    100727     128930
     8     150398         1000000      1000000     1000000      91530    120341     158315       88730    117541     155515
     9     173668         1000000      1000000     1000000     100843    137053     186782       98443    134653     184382
    10     198102         1000000      1000000     1000000     109597    154091     217796      107597    152091     215796

    11     223757         1000000      1000000     1000000     117705    171386     251558      116105    169786     249958
    12     250695         1000000      1000000     1000000     125288    189070     288490      124088    187870     287290
    13     278979         1000000      1000000     1000000     132259    207081     328874      131459    206281     328074
    14     308678         1000000      1000000     1000000     138531    225360     373048      138131    224960     372648
    15     339862         1000000      1000000     1000000     144222    244042     421558      144222    224042     421558

    20     520789         1000000      1000000     1000000     164007    345156     751285      164007    345156     751285
    25     751702         1000000      1000000     1362530     151963    449820    1297647      151963    449820    1297647
    30    1046412         1000000      1000000     2280735      46519    529397    2172129       46519    529397    2172129
    35    1422545               0      1000000     3716419          0    526059    3539447           0    526059    3539447
    40    1902596               0      1000000     5931790          0    341804    5649324           0    341804    5649324
    45    2515277               0            0     9069560          0         0    8979762           0         0    8979762

(1) Assumes no policy loans or partial withdrawals have been made.

(2) Assumes a $15,000 premium is paid at the beginning of each policy year.  Values will be different if premiums are paid in
    different amounts or with a different frequency.

The above hypothetical investment results are illustrative only and should not be deemed a representation of past or future
investment results.  Actual investment results may be more or less than those shown.  The death benefit, policy value and cash
surrender value would be different from those shown if returns averaged 0%, 6%, and 12% over a period of years, but fluctuated
above and below those averages for individual policy years.  No representation can be made that these hypothetical rates of return
can be achieved for any one year or sustained over any period of time.
<PAGE>
PAGE 88
Illustration                                                                                                                
_____________________________________________________________________________________________________________________________
Initial specified amount $1,000,000            Male -   Insurance age 55 - Nonsmoker               Guaranteed costs assumed
Death benefit Option 1                         Female - Insurance age 55 - Nonsmoker                annual premium $15,000
_____________________________________________________________________________________________________________________________
           Premium          Death benefit (1)(2)               Policy value (1)(2)               Cash surrender value (1)(2)
           accumulated      assuming hypothetical gross        assuming hypothetical gross       assuming hypothetical gross
End of     with annual      annual investment return of        annual investment return of       annual investment return Of
policy     interest
year       at 5%          0%           6%          12%         0%        6%        12%          0%        6%        12%
_____________________________________________________________________________________________________________________________
     1      15750         1000000      1000000     1000000      12651     13424      14196        8651      9424      10196
     2      32288         1000000      1000000     1000000      25091     27415      29830       21091     23415      25830       
     3      49652         1000000      1000000     1000000      37208     41880      46926       33208     37880      42926
     4      67884         1000000      1000000     1000000      48899     56727      65520       44899     52727      61520
     5      87029         1000000      1000000     1000000      60287     72093      85888       56287     68093      81888

     6     107130         1000000      1000000     1000000      71159     87781     107990       67559     84181     104390
     7     128237         1000000      1000000     1000000      81642    103927     132130       78442    100727     128930
     8     150398         1000000      1000000     1000000      91530    120341     158315       88730    117541     155515
     9     173668         1000000      1000000     1000000     100843    137053     186782       98443    134653     184382
    10     198102         1000000      1000000     1000000     109492    153988     217697      107492    151988    215697

    11     223757         1000000      1000000     1000000     117288    170973     251160      115688    169373     249560
    12     250695         1000000      1000000     1000000     124256    188039     287501      123056    186839     286301
    13     278979         1000000      1000000     1000000     130212    205026     326914      129412    204226     326114
    14     308678         1000000      1000000     1000000     135078    221870     369736      134678    221470     369336
    15     339862         1000000      1000000     1000000     138775    238514     416371      138775    238514     416371

    20     520789         1000000      1000000     1000000     129561    310821     724728      129561    310821     724728
    25     751702         1000000      1000000     1302265      23194    325124    1240252       23194    325124    1240252
    30    1046412               0      1000000     2163670          0    167003    2060638           0    167003    2060638
    35    1422545               0            0     3476898          0         0    3311332           0         0    3311332
    40    1902596               0            0     5409153          0         0    5151574           0         0    5151574
    45    2515277               0            0     7983928          0         0    7904879           0         0    7904879

(1) Assumes no policy loans or partial withdrawals have been made.

(2) Assumes a $15,000 premium is paid at the beginning of each policy year.  Values will be different if premiums are paid in
    different amounts or with a different frequency.

The above hypothetical investment results are illustrative only and should not be deemed a representation of past or future
investment results.  Actual investment results may be more or less than those shown.  The death benefit, policy value and cash
surrender value would be different from those shown if returns averaged 0%, 6%, and 12% over a period of years, but fluctuated
above and below those averages for individual policy years.  No representation can be made that these hypothetical rates of return
can be achieved for any one year or sustained over any period of time.
<PAGE>
PAGE 89
Illustration                                                                                                                
_____________________________________________________________________________________________________________________________
Initial specified amount $1,000,000            Male -   Insurance age 55 - Nonsmoker               Current costs assumed
Death benefit Option 2                         Female - Insurance age 55 - Nonsmoker                annual premium $15,000
_____________________________________________________________________________________________________________________________
           Premium          Death benefit (1)(2)               Policy value (1)(2)               Cash surrender value (1)(2)
           accumulated      assuming hypothetical gross        assuming hypothetical gross       assuming hypothetical gross
End of     with annual      annual investment return of        annual investment return of       annual investment return Of
policy     interest
year       at 5%          0%           6%          12%         0%        6%        12%          0%        6%        12%
_____________________________________________________________________________________________________________________________
     1      15750         1012650      1013422     1014195      12650     13422      14195        8650      9422      10195
     2      32288         1025086      1027410     1029825      25086     27410      29825       21086     23410      25825
     3      49652         1037195      1041864     1046909      37195     41864      46909       33195     37864      42909
     4      67884         1048862      1056683     1065469      48862     56683      65469       44862     52683      61469
     5      87029         1060214      1072004     1085780      60214     72004      85780       56214     68004      81780

     6     107130         1071019      1087604     1107768      71019     87604     107768       67419     84004     104168
     7     128237         1081406      1103617     1131726      81406    103617     131726       78206    100417     128526
     8     150398         1091143      1119816     1157604      91143    119816     157604       88343    117016     154804
     9     173668         1100242      1136207     1185594     100242    136207     185594       97842    133807     183194
    10     198102         1108715      1152801     1215912     108715    152801     215912      106715    150801     213912

    11     223757         1116452      1169483     1248666     116452    169483     248666      114852    167883     247066
    12     250695         1123585      1186379     1284229     123585    186379     284229      122385    185179     283029
    13     278979         1130005      1203375     1322758     130005    203375     322758      129205    202575     321958
    14     308678         1135607      1220355     1364430     135607    220355     364430      135207    219955     364030
    15     339862         1140521      1237439     1409686     140521    237439     409686      140521    237439     409686

    20     520789         1154361      1323780     1703041     154361    323780     703041      154361    323780     703041
    25     751702         1130471      1388619     2131448     130471    388619    1131448      130471    388619    1131448
    30    1046412         1007126      1352982     2694292       7126    352982    1694292        7126    352982    1694292
    35    1422545               0      1067303     3330814          0     67303    2330814           0     67303    2330814
    40    1902596               0            0     4052478          0         0    3052478           0         0    3052478
    45    2515277               0            0     4424523          0         0    3424523           0         0    3424523

(1) Assumes no policy loans or partial withdrawals have been made.

(2) Assumes a $15,000 premium is paid at the beginning of each policy year.  Values will be different if premiums are paid in
    different amounts or with a different frequency.

The above hypothetical investment results are illustrative only and should not be deemed a representation of past or future
investment results.  Actual investment results may be more or less than those shown.  The death benefit, policy value and cash
surrender value would be different from those shown if returns averaged 0%, 6%, and 12% over a period of years, but fluctuated
above and below those averages for individual policy years.  No representation can be made that these hypothetical rates of return
can be achieved for any one year or sustained over any period of time.
<PAGE>
PAGE 90
Illustration                                                                                                                
_____________________________________________________________________________________________________________________________
Initial specified amount $1,000,000            Male -   Insurance age 55 - Nonsmoker               Guaranteed costs assumed
Death benefit Option 2                         Female - Insurance age 55 - Nonsmoker                annual premium $15,000
_____________________________________________________________________________________________________________________________
           Premium          Death benefit (1)(2)               Policy value (1)(2)               Cash surrender value (1)(2)
           accumulated      assuming hypothetical gross        assuming hypothetical gross       assuming hypothetical gross
End of     with annual      annual investment return of        annual investment return of       annual investment return Of
policy     interest
year       at 5%          0%           6%          12%         0%        6%        12%          0%        6%        12%
_____________________________________________________________________________________________________________________________
     1      15750         1012650      1013422     1014195      12650     13422      14195        8650      9422      10195
     2      32288         1025086      1027410     1029825      25086     27410      29825       21086     23410      25825
     3      49652         1037195      1041864     1046909      37195     41864      46909       33195     37864      42909
     4      67884         1048862      1056683     1065469      48862     56683      65469       44862     52683      61469
     5      87029         1060214      1072004     1085780      60214     72004      85780       56214     68004      81780

     6     107130         1071019      1087604     1107768      71019     87604     107768       67419     84004     104168
     7     128237         1081406      1103617     1131726      81406    103617     131726       78206    100417     128526
     8     150398         1091143      1119816     1157604      91143    119816     157604       88343    117016     154804
     9     173668         1100242      1136207     1185594     100242    136207     185594       97842    133807     183194
    10     198102         1108596      1152679     1215786     108596    152679     215786      106596    150679     213786

    11     223757         1115980      1168989     1248149     115980    168989     248149      114380    167389     246549
    12     250695         1122410      1185130     1282904     122410    185130     282904      121210    183930     281704
    13     278979         1127665      1200852     1320041     127665    200852     320041      126865    200052     319241
    14     308678         1131648      1216014     1359674     131648    216014     359674      131248    215614     359274
    15     339862         1134260      1230470     1401932     134260    230470     401932      134260    230470     401932  

    20     520789         1114956      1277423     1648090     114956    277423     648090      114956    277423     648090
    25     751702               0      1217641     1912766          0    217641     912766           0    217641     912766
    30    1046412               0            0     2085053          0         0    1085053           0         0    1085053
    35    1422545               0            0     1925001          0         0     925001           0         0     925001
    40    1902596               0            0     1056450          0         0      56450           0         0      56450
    45    2515277               0            0           0          0         0          0           0         0          0

(1) Assumes no policy loans or partial withdrawals have been made.

(2) Assumes a $15,000 premium is paid at the beginning of each policy year.  Values will be different if premiums are paid in
    different amounts or with a different frequency.

The above hypothetical investment results are illustrative only and should not be deemed a representation of past or future
investment results.  Actual investment results may be more or less than those shown.  The death benefit, policy value and cash
surrender value would be different from those shown if returns averaged 0%, 6%, and 12% over a period of years, but fluctuated
above and below those averages for individual policy years.  No representation can be made that these hypothetical rates of return
can be achieved for any one year or sustained over any period of time.
</TABLE>  
    

56. If the trust is the issuer of periodic payment plan
    certificates, furnish by years for the period covered by the
    financial statements filed herewith in respect of
    certificates sold during such period, the following
    information for each fully paid type of each installment
    payment type of periodic payment plan certificate currently
    being issued by the trust.

    Not applicable.

57. If the trust is the issuer of periodic payment plan
    certificates, furnish by years for the period covered by the
    financial statements filed herewith the following information
    for each installment payment type of periodic payment plan
    certificate currently being issued by the trust.

    Not applicable.
<PAGE>
PAGE 91
58. If the trust is the issuer of periodic payment plan
    certificates, furnish the following information for each
    installment type of periodic payment plan certificate
    outstanding as of the latest practicable date.

    Not applicable.

59. Financial Statements:

    Financial Statements of the Trusts

    Financial Statements of the Accounts 

    The unaudited financial statements of IDS Life Variable Life
    Separate Account (comprising, respectively, the U, V, W, X, Y
    and IL subaccounts) for the six month period ended June 30,
    1995. The unaudited financial statements together with the
    auditied financial statements for the fiscal year ended
    December 31, 1994 are included with Amendment No. 1 to the
    Registration Statement on Form S-6 (File No. 33-62457) filed
    by the Registrant pursuant to the Securities Act of 1933 on
    the same date as the filing of Amendment No. 5 to this
    Registration Statement.  Upon such filing, these financial
    statements together with the opinion of Ernst & Young, LLP,
    independent public accountants, will be incorporated herein
    by reference. 

    Financial Statements of the Depositor

    The following financial statements of IDS Life Insurance
    Company, together with the opinion of Ernst & Young, LLP,
    independent public accountants, are included in the Amendment
    No. 1 to the Registration Statement on Form S-6 (File No. 33-
    62457) filed by the Registrant pursuant to the Securities Act
    of 1933 on the same date as the filing of Amendment No. 5 to
    this Registration Statement and upon such filing, such
    statements will be incorporated herein by reference:

    Consolidated Balance Sheet - as of December 31, 1994.*
    Consolidated Statement of Income - as of December 31, 1994.*
    Consolidated Statements of Cash Flows - as of December 31,
    1994.*
    Notes to Consolidated Financial Statements*

    *Includes unaudited financial statements and notes for six-
    month period ended June 30, 1995.

EXHIBITS -

A. (1) Resolution of Board of Directors of IDS Life authorizing the
Trust.*
   (2) Not applicable.
   (3) (a) Not applicable.
       (b) Form of
           (1) Division Vice President's Employment
               Agreement**<PAGE>
PAGE 92
           (2) District Sales Manager's Rider to IDS Life Insurance
               Company, Personal Financial Planner's Agreement**
           (3) Personal Financial Planner's Agreement**
       (c) Schedules of Sales Commissions are filed electronically
           herewith.
   (4) Not applicable.
   (5) (a) Single Premium Variable Life Insurance Policy*
       (b) Flexible Premium Variable Life Insurance Policy*
       (c) Flexible Premium Survivorship Variable Life Insurance
           Policy is filed electronically herewith.
   (6) (a) Certificate of Incorporation of IDS Life**
       (b) Amended Bylaws of IDS Life**
   (7) Not applicable.
   (8) (a) Form of Investment Management and Services
           Agreement between IDS Life and IDS Life Series
           Fund, Inc.**
       (b) Form of Investment Advisory Agreement between IDS
           Life and IDS Financial Services, Inc. relating to
           the Variable Account**
       (c) Addendum to Investment Management and Services
           Agreement is filed electronically herewith.
       (d) Addendum to Investment Advisory Agreement is filed
           electronically herewith.
   (9) None.
  (10) (a) Application form for the Single Premium Variable
           Life Insurance Policy.*
       (b) Application form for the Flexible Premium
           Variable Life Insurance Policy.*
       (c) Application form for the Flexible Premium Survivorship
           Variable Life Insurance Policy is filed electronically
           herewith.
  (11) Memorandum on Transfer and Redemption Procedures, and
       Method of Computing Adjustments on Conversions filed
       electronically herewith.
  (12) Power of attorney dated February 28, 1995.**
B. (1) Not applicable.
   (2) Not applicable.
C. Not applicable.

 *Filed as an Exhibit to the original Registration
  Statement and/or Amendments No. 1 or 2 thereto
  (Form 811-4298)
**Filed as an Exhibit to Amendment No. 4 of the original
  Registration Statement to form N-8B-2 File No. 811-4298.
<PAGE>
PAGE 93
Pursuant to the requirements of the Investment Company Act of 1940,
the depositor of the Registrant has cause this Amendment No. 5 to
the Registration Statement to be duly signed on behalf of the
Registrant in Minneapolis, Minnesota on September 21, 1995.

IDS Life VARIABLE LIFE SEPARATE ACCOUNT

BY IDS Life INSURANCE COMPANY
(Depositor)


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



By___________________________
    Mary Ellyn Minenko


Attest:______________________
              (name)

       ______________________
              (title)

Pursuant to the requirements of the Securities Act of 1933, this
Registration Statement has been signed by the following Officers
and Directors of IDS Life Insurance Company in the capacities
indicated on the 21st day of September, 1995:

Signature                          Title

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

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

/s/ Louis C. Fornetti*             Director
    Louis C. Fornetti

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

/s/ Paul F. Kolkman*               Director and Executive Vice
    Paul F. Kolkman                President

/s/ Peter A. Lefferts*             Director and Executive Vice
    Peter A. Lefferts              President, Marketing

/s/ Janis E. Miller*               Director and Executive Vice
    Janis E. Miller                President, Variable Assets

/s/ Barry J. Murphy*               Director and Executive Vice
    Barry J. Murphy                President, Client Service<PAGE>
PAGE 94
Signature                          Title

/s/ Stuart A. Sedlacek*            Director and Executive Vice
    Stuart A. Sedlacek             President, Assured Assets

/s/ Melinda S. Urion*              Director, Executive Vice
    Melinda S. Urion               President and Controller


*Signed pursuant to Power of Attorney dated February 28, 1995,
filed electronically as Exhibit No. 12 to Registration Statement
Amendment No. 4 to form N-8B-2 file No. 811-4298.

By:



                           
    Mary Ellyn Minenko




IDS LIFE VARIABLE LIFE SEPARATE ACCOUNT
Registration Number 811-4298

EXHIBIT INDEX

Exhibit A3(c) Schedules of Sales Commissions.

Exhibit A5(c) Flexble Premium Survivorship Variable Life
              Insurance Policy.

Exhibit A8(c) Addendum to Investment Management and Services
              Agreement.

Exhibit A8(d) Addendum to Investment Advisory Agreement.

Exhibit A10(c)Application form for Flexible Premium
              Survivorship Variable Life Insurance Policy.

Exhibit 11    IDS Life Insurance Company's Description of
              Transfer and Redemption Procedures and Method of
              Conversion to Fixed Benefit Policies.

<PAGE>
PAGE 1
Commission and production schedules

Life Insurance

Variable Second-to-Die Life Insurance (V2D)

Star Quest   X
Persistency Standard  87%
<TABLE><CAPTION>
Variable(s)                         Commission                         Production                    

                     Percent of            Percent of                                  Premiums paid
                    premium up to        premium paid in                                in excess of
Category                Target           excess of Target         Target X factor     Target X factor
<S>                     <C>                    <C>                       <C>                 <C>  
All ages                50%                    2.0%                      28                  1.1


Variable(s)                       Client Service Commissions                                         

Year                           Commission per $1,000 market value of the
                               average quarterly cash value** (less loans)                           

1+                                       $1.25*

* Paid quarterly (i.e., $.3125 per $1,000 each quarter).  Quarterly service fee is paid when the 
quarterly client consolidated statement is printed.
**Average quarterly cash value (less loans) is calculated by taking the market value of the cash
value from the previous and current quarter's consolidated statement and dividing by two.
</TABLE>

New Business Commissions

Credited to the selling advisor(s) with weighted production up to
the target premium.  Credited to the servicing advisor(s) on
payments made in excess of the target premium.

Client Service Commissions

Client Service Commissions are credited to the servicing advisor(s)
on the market value of the cash value.

Example(s):

a.  If the target premium is $8,000 and the entire amount has
    been paid, commissions and weighted production would be
    calculated as follows:

    Commissions                      Production          
     $8,000 x 50% = $4,000            $8,000 x 28 = 224,000
<PAGE>
PAGE 2
b.  If the target premium is $8,000 and a $10,000 premium is
    applied, commissions and weighted production would be
    calculated as follows:

    Commissions                      Production          
     Target: $8,000 x 50% = $4,000    $8,000 x 28  = 224,000
     Excess: $2,000 x 2%  =     40    $2,000 x 1.1 =   2,200
                            $4,040                  $226,200

c.  If the selling advisor in Examples a. and b. is a second-year
    advisor in his or her 45th service period, Supplemental
    Commissions would be calculated as follows (assumes the
    advisor is meeting PVS and FPR):
<TABLE><CAPTION>
    Supplemental Commissions                                    
     <S>                                                     <C>
     $4,040 (commissions earned) x 15% (Supplemental rate) = $606

    Total commissions earned                                    
     $4,040 (commissions earned) x $606 (Supplemental Commissions) = $4,646
</TABLE>
V2D Life Insurance Guidelines

1.  Annualization

    a.   What are the criteria for annualization?

         Commissions will annualize if accounts are submitted
         with money and set up with a bank authorization (BA),
         group billing, special payment option (SPO) from Cash
         Management or Tax-Free Money Fund, military allotment
         (MA) or payroll deduction.  Annualized commissions  are
         not credited on payroll deductions for American Express
         financial advisors or corporate office employees.

    b.   How is the compensation base determined?

         Annualized commissions are based on the lesser of the
         target premium or the systematic payment times
         frequency up to a maximum of $1,500.  (Exception:  If a
         group bill is set up as a percent of the client's total
         group bill, annualized commissions will be calculated
         based on the lesser of the target premium or $1,500.)

    c.   When does it annualize?

         Annualized commissions will be credited when the policy
         is submitted with money and the systematic billing is
         set up.  (Exceptions:  MAs will annualize without
         submitted money.  SPOs are set up when the policy is
         issued; therefore, annualized commissions are not
         credited until the policy is issued.)  Commissions will
         also annualize up to the target premium if the
         systematic billing is set up in the first contract year
         before the target premium is met.
<PAGE>
PAGE 3
    d.   What is the maximum annualized compensation?

         Annualized commissions are limited to $1,500 per
         account.

    e.   What causes adjustments?

         If payments decrease, the annualized commissions will
         be adjusted.  If payments increase, the time required
         to reduce the amount of unearned annualized commissions
         will decrease.  If the systematic payment is stopped,
         all unearned annualized commissions will be reversed. 
         If the policy lapses or is surrendered, the advisor
         will lose all unearned annualized commissions and
         weighted production.

2.  Compensation timing

    Compensation is credited after business is processed.
<TABLE><CAPTION>
              <S>             <C>
          New business:Up to two business days for new business entries
                    Two to 60 business days for underwriting, depending on underwriting requirements
                    Up to five business days after underwriting to issue the policy

          1035 exchanges:60 business days or until the money is received from the other company

          Policy changes:Fourteen calendar days or up to 60 calendar days, depending on underwriting requirements.  IDS
                    Life credits compensation only after the policy change is completed and money is applied to the
                    account.

          Surrenders:Four business days

          Death claims:Seven calendar days
</TABLE>
    IDS Life will pay a maximum of $1,500 in commissions on
    submitted business.  If additional commissions are due, they
    will be credited once the policy is in force.  The maximum
    annualized commission of $1,500 still applies.  If additional
    commissions are due, they will be credited once the $1,500 in
    annualized commissions is earned and then subsequent
    commissions are credited as each premium is applied to the
    account.  (Exception:  Submitted business commissions will
    not be paid on personal purchases and sales to relatives;
    however, full compensation will be credited once the policy
    is in force.)

    IDS Life credits compensation on permanent ratings only after
    the policy is in force.  The company does not credit
    compensation on temporary ratings or aviation riders.

    If the client is 76 years old or older, the face amount of
    policy is more than $1 million, or if it is COD business,
    commissions, and weighted production will not be credited
    until the policy is issued.  The weighted production is
    effective on the date the policy is received in the corporate
    office.

    Weighted production on the initial sale is effective on the
    date the policy is received in the corporate office.  For<PAGE>
PAGE 4
    payments in excess of the target premium, weighted production
    is effective on the accounting date of the increase or older
    addition, it is not backdated to the date the corporate
    office received the policy change.

3.  Exit/purchase transactions

    Exit/purchase transaction rules apply only when an IDS Life
    or IDS Life of New York traditional life, LP+ or Universal
    Life policy is surrendered or lapses and another Universal
    Life policy(ies) is purchased.  When this occurs and the
    final premium due date of the lapsed or surrendered policy is
    six months before or one year after the corporate office
    receipt date of the new policy, compensation will be
    adjusted.  If a new policy replaces an existing policy(ies)
    that was in force less than nine years, the adjustment will
    consist of deducting earned GAP, MFYAP or target premium
    compensation previously paid on the old policy(ies) from
    compensation payable on the new policy.  The amount of first-
    year compensation recovered will be based on the table below. 
    Full compensation will be given on the new policy in Year 2
    and after.

    Age of old policy            Percent of first-year commission
             (years)                  of old policy to be recovered

              1-4                                  100%
                5                                   80
                6                                   60
                7                                   40
                8                                   20
                9+                                   0

    A $50 conservation fee is credited on changes to V2D Life
    from V2D Life, Universal Life, Whole Life, Term Life, Single
    Pay Life and LP+ when the adjusted commissions are less than
    $50.

    Cash-value rollovers from life insurance policies to UL or
    LP+ policies pay compensation on the rollover premium dollars
    up to the target premium.  Compensation is not credited on
    loans or partial surrenders used to pay premiums on another
    policy.  No Excess Commissions are paid on Cash-value
    rollovers.

    For example, assume that the old policy had an issue date of
    Jan. 1, 1987, and produced $100 in commissions.  The new
    policy has an issue date of June 1, 1994, and also produces
    $100 in commissions.  Since the old policy was in its eighth
    year when it was replaced, commissions paid would equal $80
    ($100 - [$100 x .20%]) and weighted production would be
    credited in the same proportions.

4.  License(s) required

    An advisor must have a life insurance license for the state
    in which the application was signed for new business<PAGE>
PAGE 5
    compensation.  For Variable Second-to-Die Life, an advisor
    must also have a Series 6 or 7 license.  In addition, some,
    but not all states require a Variable Life Insurance license
    and either a Variable Annuity license or a Variable Contracts
    license.  After the account is open, the advisor must hold
    the appropriate license(s) in the client's resident state to
    receive compensation.

5.  Persistency

    Only weighted production generated on the client's target
    premium will be measured for Star Quest persistency.  The
    persistency standard for Variable Second-to-Die Life products
    sold is 87%.  If the persistency ratio falls below this
    standard (see Section 3, Incentive and award programs), all
    Variable Second-to-Die Life production for the previous year
    will be subtracted from the current year's production when
    calculating allocations to Star Quest.

6.  Advisor/relative purchases

    No special rates are available for advisors or their
    relatives on these products; therefore, full compensation is
    credited on these sales only after the policy is in force. 
    Annualized commissions will be credited when the policy is
    issued if the account is set up on a systematic payment
    arrangement, except for payroll deductions for American
    Express financial advisors and corporate office employees.

7.  Reversals

    On applications that are withdrawn, declined or not taken, or
    if all requirements are not received in the corporate office
    within the allotted time, commissions and weighted production
    will be reversed.  IDS Life does not credit further
    compensation until the policy is re-opened, all requirements
    are received in the corporate office and the policy is placed
    in force.  If the policy lapses or is surrendered, the
    advisor will lose any unearned commissions, all target
    premium production up to 26 months from the sale date, and
    all add-on production for the previous 14 months.  Ten-day
    free looks and cancellations will result in a full reversal
    of both commissions and weighted production.  In the case of
    a death claim, the advisor will lose all unearned annualized
    commissions.  Weighted production will be reversed as of the
    sale effective date.

8.  Supplemental Commissions

    For first-, second- and third-year advisors, Supplemental
    Commissions will be credited at the following rates:<PAGE>
PAGE 6
<TABLE><CAPTION>
    Service year         Service period       Highly fronted, some deferred*
            <S>                  <C>                         <C>
            1                     1 - 26                     35%
            2                    27 - 39                     25
            2                    40 - 52                     15
            3                    53 - 78                     10

    *These rates are a percentage of New Business Commissions.       
</TABLE>
    Supplemental Commissions are credited based on the rate in
    effect at the time the business was submitted and the first
    payment was received.  For instance, if you submit business
    while you are a first-year advisor but it is not issued until
    you reach your second year, you will receive Supplemental
    Commissions at the first-year rate.

    Supplemental Commissions are credited when the policy is in
    force; they are not credited on submitted business.  For more
    information about Supplemental Commissions, refer to Section
    2, Compensation plan descriptions.

<PAGE>
PAGE 1
AMERICAN EXPRESS
FINANCIAL ADVISORS

IDS Life Insurance Company
IDS Tower 10
Minneapolis, Minnesota 55440

Flexible Premium Survivorship Variable Life Insurance Policy

- Death benefit payable at last surviving insured's death. 
- Flexible premiums payable as provided herein. 
- Death Benefit Guarantees as described herein. 
- This policy is nonparticipating.  Dividends are not payable.

Insureds:      (John Doe)            (Jane Doe)
Policy Date: (January 15, 1995)
Policy Number:    (9090-1234,567)
Initial Specified Amount:    $(250,000)

This is a life insurance policy.  It is a legal contract between
you, as the owner, and us, IDS Life Insurance Company, A Stock
Company.  Please read your policy carefully.  

In consideration of your application and payment of the initial
premium, we issue this policy and we promise to pay the proceeds
described in this policy to the beneficiary if we receive proof
satisfactory to us that the last surviving insured died while this
policy was in force.  (See "Death Benefits" on page 11.)

The owner and beneficiary are as named in the application unless
they are changed as provided in this policy.

The amount and duration of the death benefit of this policy may
increase or decrease as described herein depending on the
investment experience of the subaccounts.

The policy value of this policy may increase or decrease daily
depending on the investment experience of the subaccounts.  There
is no guaranteed minimum policy value.

Notice of your right to examine this policy. If for any reason you
are not satisfied with thls policy, return it to us or our
representative by the latest of the: 
a) 10th day after you receive it; or 
b) 10th day after we mail or personally deliver to you a written
Notice of Withdrawal Right; or 
c) 45th day after the application is signed.

We will then cancel this policy and refund all premiums that you
have paid. This policy will then be considered void from its start.
<PAGE>
PAGE 2
Signed for and issued by IDS Life Insurance Company in Minneapolis,
Minnesota, as of the policy date shown above.

President:

/s/ Richard W. Kling

Secretary:

/s/ William A. Stoltzmann<PAGE>
PAGE 3
Guide to Policy Provisions
<TABLE><CAPTION>
<S>                                     <C>
Policy Data             Important Policy Data
                        Information/Page 3  

Definitions             Important words and meanings/Page 4

Insurance Contract      Entire contract; Incontestability;
                        Suicide provision; Policy exchange;
                        Misstatement of age or sex;
                        Termination/Page 5

Owner and Beneficiary   Owner's rights; Change of ownership;
                        Beneficiary designation; Change of
                        beneficiary; Assignment/Page 7

Premiums                Payment of premiums; Premium
                        allocations; Grace period; Death
                        benefit guarantees;
                        Reinstatement/Page 8

Death Benefits          Death benefit options 1 and 2/Page 11

Policy Change           Changes to the specified amount or
                        death benefit options/Page 12

Policy Values           The policy's value and how it is
                        determined; Monthly deduction; Cost
                        of insurance; Continuation of
                        insurance; Basis of policy
                        values/Page 13

Policy Loans            How to request a loan; Interest rate;
                        Amount of loan; Loan repayment/Page
                        15

Policy Surrender        Cash surrender value; Full and
                        partial surrenders/Page 17

Subaccounts             The subaccounts; Net investment
                        factor; Deductions from the
                        subaccounts; Transfer of values/Page
                        18

Payment of Policy Proceeds    How the proceeds are paid; Payment
                              options/Page 20
/TABLE
<PAGE>
PAGE 4
Policy Data 
<TABLE><CAPTION>
Insureds    Issue Age               Risk Classifications
<S>                 <C>                        <C>
John Doe        35                  (Male Standard Nonsmoker)
Jane Doe        35                  (Female Standard Nonsmoker)

Policy Number:                      9090-(1234,567)

Type of Policy:                     Flexible Premium Survivorship
                                    Variable Life

Initial Specified Amount:           $(250,000)

Minimum Specified Amount:           $(250,000)

Initial Death Benefit Option:       (Option 1)

Guaranteed Interest Rate:           4% per year

Guaranteed Interest Rate Factor:    1.0032737

Current Loan Interest Rate:         
First policy year:                  6% per year
All other policy years:             4% per year

Guaranteed Loan Interest Rate:      6% per year

Policy Date:                        (January 15, 1995)

Monthly Date:                       (15)

Initial Premium:                    $(2413.60)

Scheduled Premium:                  $(2413.60 per year payable
                                    annually)

Minimum Initial Premium:            $(88.01) per month

Minimum Initial Premium Period:     (3) years

Death Benefit Guarantee
to age 85 premium:                  $(120.68 per month)

Death Benefit Guarantee
to age 100 premium:                 $(181.02 per month)

Premium Expense Charge:             11% of all premium payments

Policy Fee:                         $30 per month for first 15
                                    policy years

Partial Surrender Fee:              ($25.00 or 2% of amount
                                    surrendered, whichever is less)
/TABLE
<PAGE>
PAGE 5
<TABLE><CAPTION>
Table of Surrender Charges

Policy Year       Beginning of year       End of year
<S>                     <C>               <C>
1 - 5                   $1000.00          $1000.00
6                        1000.00            900.00
7                         900.00            800.00
8                         800.00            700.00
9                         700.00            600.00
10                        600.00            500.00
11                        500.00            400.00
12                        400.00            300.00
13                        300.00            200.00
14                        200.00            100.00
15                        100.00              0.00
</TABLE>
This table applies to the initial specified amount for the first 15
policy years.  After year 5, surrender charges decrease monthly. 

Coverage will expire when the policy values are insufficient to pay
the charges assessed on a monthly anniversary.  Because the policy
values may be based on the investment results of the subaccounts,
the payment of scheduled premiums or unscheduled premiums in any
amount or frequency will not guarantee that the policy will remain
in force unless the premiums needed to keep the Death Benefit
Guarantee to age 85 or the Death Benefit Guarantee to age 100 in
effect have been paid.

Investment Options                   Initial Premium Allocations
IDS Life Fixed Account                         0.000%
IDS Life Variable Life Separate Account

      Subaccounts that invest in portfolios
      ("the Portfolios") of the 
      IDS Life Series Fund, Inc.:

U     Equity Portfolio                        70.000%
V     Income Portfolio                        15.000%
W     Money Market Portfolio                   0.000% 
X     Managed Portfolio                       15.000%  
Y     Government Securities Portfolio          0.000%
IL    International Equity Portfolio           0.000%

<TABLE><CAPTION>
          Schedule of Benefits and Riders

                                                                              Annual
                              Effective Date       Expiration Date        Cost of Insurance
<S>                           <C>                  <C>                    <C> 
Flexible Premium
Survivorship Variable Life    (January 15, 1995)   See policy form        See policy form

Four-Year Term                (January 15, 1995)   (January 15, 1999)     See rider form
Insurance Rider
Amount of 
Insurance: ($305,000)
<PAGE>
PAGE 6
Policy Split                  (January 15, 1995)   (January 15, 2046)     ($180.00)
Option Rider
</TABLE>

   Guarantees Maximum Annual Cost of Insurance Rates per $1,000

Policy          Annual          Policy          Annual
Year            Rate            Year            Rate  
   1            $  .12            36            $ 11.76
   2               .12            37              13.92
   3               .12            38              16.56
   4               .12            39              19.68
   5               .12            40              23.40

   6               .12            41              27.72
   7               .12            42              32.52
   8               .12            43              38.04
   9               .12            44              44.04
  10               .12            45              50.88

  11               .12            46              58.68
  12               .12            47              67.56
  13               .12            48              77.88
  14               .24            49              89.52
  15               .24            50             102.48

  16               .36            51             116.52
  17               .36            52             131.52
  18               .48            53             147.24
  19               .60            54             163.68
  20               .72            55             180.96

  21               .84            56             199.08
  22              1.08            57             218.52
  23              1.32            58             239.76
  24              1.56            59             264.48
  25              1.80            60             296.16

  26              2.16            61             341.64
  27              2.52            62             414.12
  28              3.00            63             537.24
  29              3.60            64             743.88
  30              4.32            65             999.96

  31              5.16
  32              6.12
  33              7.32
  34              8.52
  35             10.08<PAGE>
PAGE 7
Definitions

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

accumulation unit 
An accounting unit used to calculate the policy value of the
subaccounts. It is a measure of the net investment results of each
of the subaccounts.

attained insurance age 
Each insured's insurance age plus the number of policy
anniversaries since the policy date. Attained insurance age changes
only on a policy anniversary.

cash surrender value 
The policy proceeds if the policy is surrendered in full, or the
amount payable if the last surviving insured's death occurs on or
after the youngest insured's attained insurance age 100.  It is the
policy value minus indebtedness, minus surrender charges as shown
under Policy Data.

death benefit guarantee to age 85 
A guarantee that the policy will not lapse before the youngest
insured's attained insurance age 85, or 15 policy years, if later.

death benefit guarantee to age 85 premium 
The premium required to keep the death benefit guarantee to age 85
in effect.  The death benefit guarantee to age 85 premium is shown
under Policy Data.

death benefit guarantee to age 100 
A guarantee that the policy will not lapse before the youngest
insured's attained insurance age 100.

death benefit guarantee to age 100 premium 
The premium required to keep the death benefit guarantee to age 100
in effect.  The death benefit guarantee to age 100 premium is shown
under Policy Data.

fixed account 
Our general investment account.  It is made up of our assets other
than those held in any separate account.

fixed account value 
The portion of the policy value that is allocated to the fixed
account, including indebtedness.

in force 
The insureds' lives remain insured under the terms of this policy.

indebtedness 
All existing loans on this policy plus policy loan interest that
has been accrued or added to the policy loan.
<PAGE>
PAGE 8
insurance age 
The issue age shown under Policy Data for each insured as
determined by us from the birthdates stated in the application.

insureds
The persons whose lives are insured by this policy.

last surviving insured 
The second to die of the insureds.

monthly date 
The same day each month as the policy date. If there is no monthly
date in a calendar month, the monthly date will be the first day of
the next calendar month.

net premium 
The portion of a premium paid that is credited to the policy as
described in the Policy Values section. It is the premium paid
minus the premium expense charge shown under Policy Data.

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

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

policy value 
The sum of the fixed account value and the variable account value.

premium expense charge 
The premium expense charge of 11% of all premiums paid consists of
three parts.  The parts are: 7.25% sales charge; 2.5% premium tax
charge; and 1.25% federal tax charge.  We reserve the right to
change the federal tax charge part if applicable federal law
changes our federal tax burden.

proceeds 
The amount payable by this policy as follows:

1.    upon death of the last surviving insured prior to the
      youngest insured's attained insurance age 100, proceeds will
      be the death benefit under the option in effect as of the
      date of that insured's death, minus any indebtedness; 

2.    upon the death of the last surviving insured on or after the
      youngest insured's attained insurance age 100, proceeds will
      be the cash surrender value. 

3.    upon surrender of the policy, the proceeds will be the cash
      surrender value.
<PAGE>
PAGE 9
pro-rata basis 
Allocation to the fixed account and each of the subaccounts.  It is
proportionate to the value (minus any indebtedness in  the fixed
account) that each bears to the policy value, minus indebtedness.

specified amount 
An amount used to determine the death benefit and the proceeds
payable upon death of the last surviving insured prior to the
youngest insured's attained insurance age 100. The initial
specified amount is shown under Policy Data.

subaccounts 
The subaccounts named under Policy Data.  Each is an investment
division of the variable account and invests in a particular
portfolio.

terminate 
This policy is no longer in force.  All insurance coverage under
this policy has stopped.

valuation date 
Each day on which the New York Stock Exchange is open for trading,
or any other day on which there is a sufficient degree of trading
in the investments of the subaccounts such that the current value
might be materially affected.

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

variable account value 
The sum of the values of the subaccounts under this policy.

we, our, us 
IDS Life Insurance Company.

written request 
A request in writing signed by you.

youngest insured 
The insured with the youngest issue age as shown under Policy Data.

you, your 
The owner of this policy.  The owner may be someone other than an
insured.  The owner is shown in the application unless the owner
has been changed as provided in this policy.


The Insurance Contract

What is the entire contract of insurance?

This policy and the copy of the application attached to it and any
endorsements or riders added to the policy are the entire contract
between you and us.
<PAGE>
PAGE 10
No one except one of our corporate officers (President, Vice
President, Secretary, or Assistant Secretary) can change or waive
any of our rights or requirements under this policy.  That person
must do so in writing.  None of our representatives or other
persons have the authority to change or waive any of our rights or
requirements under this policy.

In issuing this policy, we have relied upon the application.  The
statements contained in the application are considered, in the
absence of fraud, representations and not warranties.  No statement
made in connection with the application will be used by us to void
the policy or to deny a claim unless that statement is part of the
application.

When will the policy become incontestable?

After this policy has been in force during the lifetime of both
insureds for two years from the policy date, we cannot contest the
policy except for nonpayment of premiums.

Is there a suicide exclusion?

If either of the insureds die by suicide while sane or insane
within two years from the policy date, the only amount payable by
us will be the premium paid, minus any indebtedness and partial
surrenders.  The policy will terminate as of the date of the first
death by suicide.  We will pay any amount payable to you, if
living, otherwise to your estate.

Can you exchange this policy?

Yes. Once during the first two policy years, you have the right to
exchange this policy for a flexible premium life insurance policy
that provides for benefits that do not vary with the investment
return of the subaccounts.  This is done by transferring, without
charge, the entire policy value to the fixed account.

Do you have voting rights?

All policy owners with variable account values will have voting
rights.  So long as federal law requires, you may have the right to
vote at the meetings of the Variable Policy Owners.  If you have
voting rights, we will send you a notice of the time and place of
any such meetings.  The notice will also explain matters to be
voted on and how many votes you will have.

Do state laws apply?

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

What if an insured's age or sex has been misstated?

If an insured's age or sex has been misstated, the proceeds payable
upon the last surviving insured's death will be:
<PAGE>
PAGE 11
1. the policy value on the date of death; plus

2. the amount of insurance that would have been purchased by the
cost of insurance deducted for the policy month during which the
last surviving insured's death occurred, if that cost had been
calculated using the cost of insurance rates for the correct age
and sex; minus

3.  any indebtedness on the date of death.

When does this policy terminate?

This policy will terminate on the earliest of the following:

1.  the date you request that coverage ends; or

2.  the date you surrender the policy in full; or

3.  the end of the grace period; or

4.  the date of death of the last surviving insured.

Does this policy qualify for favorable tax treatment?

This policy is intended to qualify for treatment as a life
insurance policy under Sections 72, 101, and 7702 of the Internal
Revenue Code as they now exist or may later be amended.

We reserve the right to endorse this policy to comply with:

1.  future changes in the Internal Revenue Code;

2.  any regulations or rulings issued under the Code; and

3.  any other requirements imposed by the Internal Revenue Service;

with respect to remaining qualified for treatment as a life
insurance policy under these Code sections.

We will provide the owner with a copy of any such endorsement.<PAGE>
PAGE 12
Owner and Beneficiary

What are your rights as owner of this policy?

As owner, you are entitled to exercise all the rights and
privileges of this policy while either or both of the insureds are
living.

How can you change ownership of this policy?

You can change the ownership of this policy by written request on a
form approved by us.  The change must be made while an insured is
living.  Once the change is recorded by us, it will take effect as
of the date of your request, subject to any action taken or payment
made by us before the recording.

To whom are the proceeds paid on the last surviving insured's
death?  

We will pay the proceeds to the beneficiary or beneficiaries whom
you have named in the application unless you have since changed the
beneficiary as provided below.  If the beneficiary has been
changed, we will pay the proceeds in accordance with your last
change of beneficiary request.

How do you change the beneficiary?

By making a satisfactory written request to us, you may change the
beneficiary anytime while an insured is living.  Once we record the
change, it will take effect as of the date of your request, subject
to any action taken or payment made by us before the recording.

If one or all of the beneficiaries die before the last surviving
insured's death, to whom are the proceeds payable?

Only those beneficiaries who are living at the last surviving
insured's death may share in the proceeds.  If no beneficiary
survives the last surviving insured, we will pay the proceeds to
you, if living; otherwise to your estate.

Can you assign this policy as collateral?

Yes.  While an insured is living, you can assign this policy or any
interest in it.  Your interest and the interest of any beneficiary
are subject to the interest of the assignee.  An assignment is not
a change of ownership and an assignee is not an owner as these
terms are used in this policy.  We will pay any policy proceeds
payable to the assignee in a single sum.  

You must give us a copy of any assignment.  Any assignment is
subject to any action taken or payment made by us before the
assignment was recorded at our home office.  We are not responsible
for the validity of any assignment.<PAGE>
PAGE 13
                             Premiums

What are the premium payments for this policy?

Three types of premium payments apply to this policy.  We call
these:

1.  the initial premium;

2.  scheduled premiums; and

3.  unscheduled premiums.

What is the initial premium?

The initial premium is the premium due on the policy date of this
policy.

What is the scheduled premium?  Can it be changed?

The scheduled premium is the premium shown under Policy Data.  It
is payable at the stated interval that you selected in the
application.  However, no scheduled premium may be paid on or after
the youngest insured's attained insurance age 100.

The scheduled premium will serve only as an indication of your
intent as to the frequency and amount of future premium payments.
You may change the amount or interval at any time by written
request.  You may also skip scheduled premium payments.  Any change
in amount may be subject to applicable tax laws and regulations.

Scheduled premiums may be paid annually, semi-annually, or
quarterly.  Payment at any other interval must be approved by us. 
Scheduled premium payments must be at least $50.  We reserve the
right to limit the amount of any increase in scheduled premiums.

Can you make unscheduled premium payments?

Yes.  You can make additional premium payments of at least $50 at
any time prior to the youngest insured's attained insurance age
100.  We reserve the right to limit the number and amount of these
unscheduled premiums.  This includes our right to refuse such
premiums if there is indebtedness on this policy.

Where are premiums payable?

Premiums must be paid or mailed to us at our home ofice or to an
authorized agent.  We will give you a receipt if you request one. 
A check or draft given for all or part of a premium, unless paid
upon its presentation to the bank or person drawn on, will not be
considered payment.

How are premium payments allocated?

Premium payments applied to the fixed account and the subaccounts
will be allocated as specified in your application for this policy. 
You may choose any whole percentage for each account from 0% to<PAGE>
PAGE 14
100%.  By written request, you may change this allocation.  The
change will be effective for all premiums received after our
receipt of the change.  Premiums received before the policy date
will be allocated initially to the fixed account.  On the policy
date, the policy value in the fixed account will be transferred to
the subaccounts or remain in the fixed account in accordance with
your premium allocation percentages.  For any premium received on
or after the policy date, the premium will be allocated in
accordance with your premium allocation percentages.

Can we restrict premium payments? 

We reserve the right to refuse premiums and to return premiums with
interest if such premiums would disqualify your policy from:

1. treatment as a life insurance policy under Code Sections 72,
101, and 7702; or

2. favorable tax treatment under Code Sections 72 and 101.  

Is there a grace period for paying premiums?   

Yes.  If, on a monthly date, the cash surrender value is less than
the monthly deduction for the policy month following such monthly
date, a grace period of 61 days will begin.

The grace period will give you time to pay a premium sufficient to
continue your coverage.  We will mail, to your last known address,
a notice as to the premium needed so that the next three monthly
deductions can be made.

If the premium is not paid within the grace period, all coverage
under this policy will terminate without value at the end of the
61-day grace period.

If the last surviving insured's death occurs during the grace
period and benefits become payable under the policy, any overdue
monthly deductions will be deducted from the proceeds.

If a death benefit guarantee is in effect as described in the
provisions below, the policy will not enter the grace period.  In
addition, to allow you the opportunity to increase your policy
value gradually so that the cash surrender value is sufficient to
pay the monthly deduction, you may choose to pay only the minimum
initial premium during the minimum initial premium period as long
as the policy value minus indebtedness equals or exceeds the
monthly deduction.  The policy will not enter the grace period
during the minimum initial premium period as shown under Policy
Data, if:

1.    on a monthly date, the policy value minus indebtedness equals
      or exceeds the monthly deduction for the policy month
      following such monthly date; and

2.    the sum of all premiums paid, minus any partial surrenders,
      and minus any indebtedness equals or exceeds the minimum<PAGE>
PAGE 15
      initial premium, as shown under Policy Data, times the number
      of months since the Policy Data, including the current month.

What are the death benefit guarantees?

The death benefit guarantees described below will protect the
policy from lapsing even if the cash surrender value is
insufficient to pay the monthly deduction on a monthly date. 
Sufficient premiums as described in the provision must be paid to
keep the death benefit guarantees in effect.

What is the death benefit guarantee to age 85?

Until the youngest insured's attained insurance age 85, or 15 years
from the policy date, whichever is later, this policy will not
terminate even if the cash surrender value is insufficient to pay
the monthly deduction on a monthly date if the death benefit
guarantee to age 85 is in effect.

The death benefit guarantee to age 85 will remain in effect if, on
each monthly date, (a) equals or exceeds (b) where:

(a)   is the sum of all premiums paid, minus any partial
      surrenders, and minus any indebtedness; and

(b)   is the death benefit guarantee to age 85 premium, as shown
      under Policy Data, times the number of months since the
      Policy Date, including the current month.

Premiums may be paid on other than a monthly basis as long as the
sum of premiums paid is at least equal to the total required death
benefit guarantee to age 85 premiums at all times.

If on a monthly date, sufficient premiums have not been paid to
maintain the death benefit guarantee to age 85, an additional
period of 61 days will be allowed for the payment of a premium
sufficient to keep the death benefit guarantee to age 85 in effect. 
If the premium is not paid within this period, the death benefit
guarantee to age 85 provision will no longer be in effect, and
cannot be reinstated.  Your policy will also lapse, as described in
the "Is there a grace period for paying premiums" provision, if the
cash surrender value is insufficient to pay the monthly deduction
on a monthly date.

The death benefit guarantee to age 85 premium will change if:  1)
the specified amount is decreased; 2) the death benefit option is
changed; or 3) riders are changed or terminated.  The new death
benefit guarantee to age 85 premium will apply from the date of the
change.

What is the death benefit guarantee to age 100?

Until the youngest insured's attained insurance age 100, this
policy will not terminate even if the cash surrender value is
insufficient to pay the monthly deduction on a monthly date if the
death benefit guarantee to age 100 is in effect.
<PAGE>
PAGE 16
The death benefit guarantee to age 100 will remain in effect if, on
each monthly date, (a) equals or exceeds (b) where:

(a)   is the sum of all premiums paid, minus any partial
      surrenders, and minus any indebtedness; and

(b)   is the death benefit guarantee to age 100 premium, as shown
      under Policy Data, times the number of months since the
      Policy Date, including the current month.  

Premiums may be paid on other than a monthly basis as long as the
sum of premiums paid is at least equal to the total required death
benefit guarantee to age 100 premiums at all times.

If on a monthly date, sufficient premiums have not been paid to
maintain the death benefit guarantee to age 100, an additional
period of 61 days will be allowed for the payment of a premium
sufficient to keep the death benefit guarantee to age 100 in
effect.  If the premium is not paid within this period, the death
benefit guarantee to age 100 provision will no longer be in effect,
and cannot be reinstated.  Your policy will also lapse if, as
described in the "Is there a grace period for paying premiums"
provision, the death benefit guarantee to age 85 is not in effect
and the cash surrender value is insufficient to pay the monthly
deduction on a monthly date.

The death benefit guarantee to age 100 premium will change if: 1)
the specified amount is decreased; 2) the death benefit option is
changed; or 3) riders are changed or terminated.  The new death
benefit guarantee to age 100 premium will apply from the date of
the change.

Can you ever reinstate this policy?

This policy may be reinstated within 5 years after the end of the
grace period, unless it was surrendered for cash.  To do this, we
will require all of the following:

1.    your written request to reinstate the policy;

2.    evidence that both insureds remain insurable, or evidence for
      the last surviving insured and due proof that the first death
      occurred before the date of lapse;

3.    payment of a premium that will keep the policy in force for
      at least 3 months;

4.    payment of the monthly deductions that were not collected
      during the grace period; and

5.    payment or reinstatement of any indebtedness.

Surrender charges will also be reinstated.

The effective date of a reinstated policy will be the monthly date
on or next following the date on which we approve the application
for reinstatement.<PAGE>
PAGE 17
The suicide and incontestability periods will apply from the
effective date of reinstatement.  We will have two years from the
effective date of reinstatement to contest the truth of statements
or representations in the reinstatement application.

The death benefit guarantees will not be reinstated.  <PAGE>
PAGE 18
                          Death Benefits

What are the proceeds payable upon death of the last surviving
insured prior to the youngest insured's attained insurance age 100?

The proceeds payable upon the death of the last surviving insured
will be the death benefit in effect on the date of that insured's
death, minus any indebtedness.  The death benefit will be
calculated based on the death benefit option and specified amount
in effect as of the last surviving insured's death.  One of two
options will apply:  Option 1 or 2.  Both options are described
below.

What is Option 1?

The death benefit under this option will be the greater of:

1.    the specified amount; or

2.    the percentage of policy value from the table below on the
      date of the last surviving insured's death if death occurs on
      a valuation date, or on the next valuation date following the
      date of death.

The initial specified amount is shown under Policy Data.  Such
amount may be changed as explained in the Policy Change section.  A
partial surrender will reduce the specified amount.

What is Option 2?

The death benefit under this option will be the greater of:

1.    the policy value of this policy, plus the specified amount; 
      or

2.    the percentage of policy value from the table below on the
      date of the last surviving insured's death if death occurs on
      a valuation date, or on the next valuation date following the
      date of death.

The initial specified amount is shown under Policy Data.  Such
amount may be changed as explained in the Policy Change section.

The youngest insured's attained insurance age in the table below
refers to the youngest life insured or the age such person would
have reached.
<PAGE>
PAGE 19
<TABLE><CAPTION>
Youngest                     Youngest                     Youngest
Insured's     Applicable     Insured's     Applicable     Insured's     Applicable
Attained      Percentage     Attained      Percentage     Attained      Percentage
Insurance     of Policy      Insurance     of Policy      Insurance     of Policy
   Age          Value           Age          Value           Age          Value   
<S>              <C>            <C>           <C>            <C>          <C>      
40 or less       250            53            164            67           118
41               243            54            157            68           117
42               236            55            150            69           116
43               229            56            146            70           115
44               222            57            142            71           113
45               215            58            138            72           111
46               209            59            134            73           109
47               203            60            130            74           107
48               197            61            128            75-95        105
49               191            62            126            96           104
50               185            63            124            97           103
51               178            64            122            98           102
52               171            65            120            99           101
                                66            119           100           100
</TABLE>

The percentage is designed to ensure that the policy meets the
provisions of Federal tax law which require a minimum death benefit
in relation to policy value for the policy to qualify as life
insurance.

What are the proceeds payable upon death of the last surviving
insured on or after the youngest insured's attained insurance age
100?

The proceeds payable upon the death of the last surviving insured
will be the cash surrender value.
<PAGE>
PAGE 20
                           Policy Change

Can you request to change the benefits of this policy?

Yes.  While this policy is in force, you may request to decrease
the specified amount. You may also change the death benefit option
from 1 to 2 or from 2 to 1.  All such changes may be made only
prior to the last surviving insured's attained insurance age 100
and will be subject to the rules below.  

What are the rules for decreasing the specified amount?

You may decrease the specified amount once per policy year by
written request.  Such request may only be made after the first
policy year.  The rules are as follows:

1.    The specified amount that remains in force after a requested
      decrease may not be less than the minimum specified amount
      shown under Policy Data.

2.    We reserve the right to decline to make any specified amount
      decrease that we determine would cause this policy to fail to
      qualify as life insurance under applicable tax laws.

How do you change the death benefit option?

You may change the death benefit option once per policy year by
written request.  The change in option will be effective on the
monthly date on or next following the date we approve your request.

If the death benefit is Option 2, it may be changed to Option 1.
The new specified amount will be the Option 2 death benefit as of
the effective date of change.

If the death benefit is Option 1, it may be changed to Option 2.
The new specified amount will be the Option 1 death benefit, minus
the policy value as of the effective date of change.  

The specified amount after a change may not be less than the
minimum specified amount shown under Policy Data.

We reserve the right to decline to make any death benefit option
change that we determine would cause this policy to fail to qualify
as life insurance under applicable tax laws.

<PAGE>
PAGE 21
                           Policy Values

What is the policy's value?

On a given date, the policy value is equal to the fixed account
value plus the variable account value.

What is the fixed account value?

On the policy date, the fixed account value equals: 1) the portion
of the initial net premium allocated to the fixed account, plus any
interest credited on such portion before the policy date; minus 2)
the portion of the monthly deduction allocated to the fixed account
for the first policy month.

On any subsequent date, the fixed account value will be calculated
as:
                           a + b + c-d-e

where:

(a)   is the fixed account value on the preceding monthly date plus
      interest thereon from the preceding monthly date to the date
      of calculation;

(b)   is the portion of net premiums allocated to the fixed account
      and received since the preceding monthly date, plus interest
      on such portions from the date such net premiums were
      received to the date of calculation;

(c)   is the amount of any transfers from the subaccounts,
      including loan transfers, to the fixed account since the
      preceding monthly date, plus interest on such transferred
      amounts from the effective dates of such transfers to the
      date of calculation;

(d)   is the amount of any transfers from the fixed account,
      including loan repayment transfers, to the subaccounts since
      the preceding monthly date, plus interest on such transferred
      amounts from the effective dates of such transfers to the
      date of calculation; and

(e)   is the amount of any partial surrenders and partial surrender
      fees allocated to the fixed account since the preceding
      monthly date, plus interest on such surrendered amounts from
      the effective date of such partial surrenders to the date of
      calculation.

If the date of calculation is a monthly date, the fixed account
value will also be reduced by the portion of the monthly deduction
allocated to the fixed account for the policy month following the
monthly date.

What is the variable account value?

The variable account value is the sum of the values of the
subaccounts under this policy as shown under Policy Data.<PAGE>
PAGE 22
On the policy date, the value of each subaccount equals:  1) the
portion of the initial net premium allocated to the subaccount,
plus any interest credited on such portion before the policy date;
minus 2) the portion of the monthly deduction allocated to the
subaccount for the first policy month.

On any subsequent date the value of each subaccount will be
calculated as described below if that subsequent date is a
valuation date.  If that subsequent date is not a valuation date,
the value of each subaccount will be calculated on the next
valuation date.

On any valuation date, the value of each subaccount will be
calculated as:

                       a + b + c - d - e - f

where:

(a)   is the value of the subaccount on the preceding valuation
      date, multiplied by the net investment factor for the current
      valuation period;

(b)   is the net premiums received and allocated to the subaccount
      during the current valuation period;

(c)   is the amount of any transfers from other subaccounts or the
      fixed account, including loan repayment transfers, to the
      subaccount during the current valuation period;

(d)   is the amount of any transfers to other subaccounts or the
      fixed account, including loan transfers, from the subaccount
      during the current valuation period;

(e)   is the amount of partial surrender and partial surrender fee
      allocated to the subaccount during the current valuation
      period;

(f)   is the portion of any monthly deduction during the current
      valuation period allocated to the subaccount for the policy
      month following the monthly date.

What is the monthly deduction?

A deduction will be made each monthly date prior to the youngest
insured's attained insurance age 100 for the cost of insurance,
policy fee, and the cost of any riders for the policy month
following such monthly date.  The monthly deduction for a policy
month will be calculated as:

                          (a) + (b) + (c)
<PAGE>
PAGE 23
where:

(a)   is the cost of insurance for the policy month;

(b)   is the policy fee shown under Policy Data.  We reserve the
      right to change the policy fee, but it will never exceed $30
      per month for the first 15 policy years; and

(c)   is the cost of any policy riders for the policy month.

The monthly deduction will be taken from the fixed account and the
subaccounts according to the monthly deduction allocation
percentages specified in your application for this policy.  You   
may choose any whole percentage for each account from 0% to 100%.
By written request, you may change the percentages. Any change will 
be effective for monthly deductions taken thereafter.

The monthly deduction will be taken from the fixed account and the
subaccounts on a pro-rata basis if:  1) the value in the fixed
account or in any subaccount is insufficient to pay the portion of
the monthly deduction so allocated; or 2) you do not specify the
account or subaccounts from which the monthly deduction is to be
taken.

How is the cost of insurance calculated?

The cost of insurance for a policy month is calculated as:      

                         {a x (b - c)} + d

where:

(a)   is the cost of insurance rate described below;

(b)   is the death benefit on the monthly date divided by the
      guaranteed interest rate factor shown under Policy Data;

(c)   is the policy value at the beginning of the policy month.  At
      this point, the policy value has been reduced by the monthly
      deduction except for the part of the monthly deduction that
      pays for the cost of insurance; and

(d)   is the amount of any flat extra insurance charges as shown
      under Policy Data.

If the policy value is included in the specified amount and there
have been changes in the specified amount, the policy value is
considered a pro-rata part of each specified amount.

What is the cost of insurance rate?

The cost of insurance rate is the rate applied to the insurance
under this policy to determine the monthly deduction.  The cost of
insurance rate used to determine the monthly deduction is the
annual cost of insurance rate divided by 12.  Cost of insurance
rates are based on each insured's sex, insurance age, risk<PAGE>
PAGE 24
classification and the number of years the policy has been in
force.

We may change the cost of insurance rates from time to time.  Any
change in the cost of insurance rate will apply to all individuals
of the same risk class as each of the insureds.  We will determine
cost of insurance rates based on our expectations as to future
mortality experience.  The cost of insurance rates will not exceed
the Guaranteed Maximum Annual Cost of Insurance Rates shown under
Policy Data.  These rates are based on the 1980 Commissioners
Standard Ordinary Smoker or Non-smoker Mortality Tables, Age Last
Birthday.

What interest rate is used to determine the fixed account value?

The guaranteed interest rate applied in the calculation of the
fixed account value is the guaranteed interest rate shown under
Policy Data.  Interest in excess of the guaranteed interest rate
may be applied in the calculation of the fixed account value at
such increased rates and in such manner as we may determine.

Interest in excess of the guaranteed interest rate shown under
Policy Data will not be applied to the portion of the policy value
that equals any indebtedness due us.

For how long will the policy value continue your insurance?

Insurance coverage under this policy and any benefits provided by
riders will be continued until the cash surrender value is
insufficient to pay the monthly deduction.  See the "Is there a
grace period for paying premiums" provision and "What are the death
benefit guarantees" provision.

What is the basis used for policy values?

Values and reserves are equal to or greater than those required by
law.  Where required, a detailed statement of the method of
computation of values and reserves has been filed with the
insurance department of the state where this policy was delivered.

Will you receive information about the values of this policy?

Yes.  At least once a year, we will send you a report that shows:

1.    the current policy value;
2.    premiums paid since the last report;
3.    all charges since the last report;
4.    indebtedness on this policy;
5.    the current cash surrender value;
6.    the current death benefit; and
7.    partial surrenders since the last report.

At any time, upon written request by you, we will provide a
projection of future death benefits and policy values.  The
projection will be based on (1) assumptions as to specified
amount(s), type of coverage option and future premium payments as<PAGE>
PAGE 25
may be specified by you, and (2) such other assumptions as are
necessary and specified by us and/or you.

                           Policy Loans

Can you borrow money on this policy?  How?

By written request or other requests acceptable to us, you may
obtain a loan from us whenever this policy has a loan value.  The
loan value of this policy is the only security required for your
loan.  A loan must be for at least $500.  We will pay interest on
the policy value loaned at the guaranteed interest rate shown under
Policy Data.

If you do not specify the accounts from which the loan is to be
made, the loan will be made from the fixed account and the
subaccounts on a pro-rata basis.

The amount of any loan and any loan interest from the subaccounts
will be transferred from the subaccounts to the fixed account.

Can we delay or suspend payment of a loan?

We will normally pay the portion of any loan from the subaccounts
within 7 days after we receive your written request in our home
office.  We have the right, however, to suspend or delay the date
of any loan from the subaccounts for any period:

1.    when the New York Stock Exchange is closed; or

2.    when trading on the New York Stock Exchange is restricted; or

3.    when an emergency exists, and as a result:

      (a)   disposal of securities held in the subaccounts is not
            reasonably practicable; or 

      (b)   it is not reasonably practicable to fairly determine
            the value of the assets of the subaccounts; or

4.    during any other period when the Securities and Exchange
      Commission, by order, so permits for the protection of
      security holders.

Rules and regulations of the Securities and Exchange Commission
will govern as to whether the conditions set forth in the above
items 2 and 3 exist.

For any loans from the fixed account, we have the right to postpone
the loan for up to 6 months unless the loan is used to pay premiums
on any policies you have with us.

What is the interest rate charged for a policy loan?

The current interest rate for policy loans is shown under Policy
Data.  We reserve the right to increase this interest rate charge,<PAGE>
PAGE 26
but it will never exceed the guaranteed loan interest rate shown
under Policy Data.

Interest is charged daily and payable at the end of the policy
year.  If interest is not paid when it is due, it will be added to
your indebtedness and charged the same interest as your loan. The
additional interest will be taken from the fixed account and the
subaccounts using the monthly deduction allocation percentages.  If
the value in the fixed account or any subaccount is insufficient to
pay the additional interest, the entire additional interest will be
taken from the fixed account and the subaccounts on a pro-rata
basis.

What is the maximum loan value of this policy?

You can borrow an amount up to 85% of the policy value minus
surrender charges.  We calculate the policy value as of the date of
the loan.  We reserve the right to include monthly deductions and
interest to pay for the loan until the next policy anniversary in
determining the maximum loan value.

When can you repay your loan?

Your loan can be repaid in full or in part at any time before the
last surviving insured's death and while this policy is in force. 
A loan that exists at the end of the grace period may not be repaid
unless this policy is reinstated.

Repayments should be clearly marked as "loan repayments";
otherwise, they will be credited as premiums. They must be in
amounts of at least $50.  They will be allocated to the fixed
account and the subaccounts according to the premium allocation
percentages in effect unless you tell us otherwise.

What if your loan is not repaid?

Failure to repay a loan or to pay loan interest will not terminate
this policy unless the cash surrender value is insufficient to pay
the monthly deduction, as provided in the Grace Period provision.
This would happen if indebtedness exceeded the policy value, minus
surrender charges.

Failure to repay a loan or to pay loan interest will reduce the
proceeds payable upon the death of the last surviving insured and,
the cash surrender value.<PAGE>
PAGE 27
                         Policy Surrender

Can you surrender this policy?

Yes. You may surrender this policy for its cash surrender value at
any time.  Your request must be in writing.  Upon surrender for the
cash surrender value, this policy will terminate.

The cash surrender value of this policy is:

1.    the policy value at the time of surrender; minus
2.    any indebtedness on this policy; minus
3.    any applicable surrender charges as shown under Policy Data.

Surrender charges are shown under Policy Data.  They apply in the
first 15 policy years.

Is a partial surrender possible?   

Yes. By written request or other requests acceptable to us, you may
partially surrender this policy for an amount less than the cash
surrender value.  Partial surrenders are subject to the rules below
and payment of the partial surrender fee shown under Policy Data. 
We reserve the right to limit the frequency of partial surrenders
you may request.

If death benefit Option 1 is in effect, both the specified amount
and the policy value will be reduced by the amount of surrender and
partial surrender fee.  If death benefit Option 2 is in effect, the
policy value will be reduced by the amount of surrender and the
partial surrender fee.

What are the rules for a partial surrender?  

The following rules will apply to any partial surrender:

1.    partial surrenders may not be made in the first policy year;

2.    the minimum amount that may be surrendered is $500;

3.    the partial surrender amount cannot exceed 85% of the full
      cash surrender value;

4.    the specified amount that remains in force may not be less
      than the minimum specified amount shown under Policy Data;

5.    the surrender amount and partial surrender fee will be
      deducted from the policy value at the time of each partial
      surrender; and

6.    we reserve the right to decline a request for a partial
      surrender that we determine would cause this policy to fail
      to qualify as life insurance under applicable tax laws.

If you do not specify the accounts from which the surrender is to
be made, the surrender will be made from the fixed account and the
subaccounts on a pro-rata basis.<PAGE>
PAGE 28
Can we delay or suspend payment of a surrender?

We will normally pay the portion of any surrendered amount from the
subaccounts within 7 days after we receive your written request in
our home office.  We have the right, however, to suspend or delay
the date of any surrender payment from the subaccounts for any
period:

1.    when the New York Stock Exchange is closed; or

2.    when trading on the New York Stock Exchange is restricted, or

3.    when an emergency exists, and as a result:

      (a)   disposal of securities held in the subaccounts is not
            reasonably practicable; or

      (b)   it is not reasonably practicable to fairly determine
            the value of the assets of the subaccounts; or

4.    during any other period when the Securities and Exchange
      Commission, by order, so permits for the protection of
      security holders.

Rules and regulations of the Securities and Exchange Commission
will govern as to whether the conditions set forth in items 2 and 3
exist.

For any surrender request from the fixed account, we have the right
to postpone the payment for up to 6 months.  If we postpone payment
more than 30 days, we will also pay you interest.  The interest
will be paid at the rate of 3% per year based on the amount
surrendered for the period of postponement.<PAGE>
PAGE 29
                            Subaccounts

What are the subaccounts?

The subaccounts are separate investment accounts of ours.  They are
named under Policy Data.  We have allocated a part of our assets
for this and certain other policies to the subaccounts.  Such
assets remain our property.  They cannot be charged, however, with
liabilities from any other business in which we may take part.  

What are the investments of the subaccounts?

Net premiums and transfers will be allocated as you specify.  Each
subaccount will buy the investment shown for that subaccount under
Policy Data or as later added or changed.

How do we value the subaccounts?

The subaccount value is determined by multiplying the number of
accumulation units credited to the subaccount by the appropriate
accumulation unit values.

What are subaccount accumulation units?

The number of accumulation units for each of the subaccounts is
found by dividing: (1) the amount allocated to the subaccount; by
(2) the subaccount's accumulation unit value for the valuation
period in which we received the premium payment, transfer request,
or partial surrender request.

What is the subaccount accumulation unit value?

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

      The accumulation unit value for a subaccount for the last
      prior valuation period is multiplied by such subaccount's net
      investment factor for the following valuation period.  The
      result is the accumulation unit value.  The value of an
      accumulation unit may increase or decrease from one valuation
      period to the next.

What is the net investment factor?  How is it determined?

The net investment factor is an index applied to measure the
investment performance of a subaccount from one valuation period to
the next.  The net investment factor may be greater or less than
one; therefore, the value of an accumulation unit may increase or
decrease.

To find the net investment factor of any such subaccount for any
valuation period, we divide (1) by (2), and subtract (3) from the
result, where:
<PAGE>
PAGE 30
(1) is the net result of:

      a.    the net asset value per share of the portfolio in which
            the subaccount invests determined at the end of the
            current valuation period; plus

      b.    the per-share amount of any dividend or capital gain
            distributions made by the investment held in the
            subaccount, if the "ex-dividend" date occurs during the
            current valuation period; plus or minus

      c.    a per-share charge or credit for any taxes reserved for
            the current valuation period that we determine to have
            resulted from the investment operations of the
            subaccount; 
(2) is the net result of:

      a.    the net asset value per share of the portfolio in which
            the subaccount invests determined at the end of the
            last prior valuation period; plus or minus

      b.    the per-share charge or credit for any taxes reserved
            for the last prior valuation period; and   

(3) is a factor representing the Mortality and Expense Risk Charge.

What deductions are made from the subaccounts?

The Mortality and Expense Risk Charge compensates us for assuming
the mortality and expense risks under this policy.  It is equal, on
an annual basis, to .9% of the daily value of the subaccounts.  The
deduction will be (1) made from each subaccount; and (2) computed
on a daily basis.

Can the investments of the subaccounts be changed?

This would happen if laws or regulations changed, the investment
became unavailable, or, in our judgement, the investment were no
longer suitable for the subaccounts.  If any of these situations
occurred, we would have the right to substitute investments other
than those shown under Policy Data.  Where required, we would first
seek the approval of the Securities and Exchange Commission and the
insurance regulator of the state where this policy is delivered.

Can transfers be made among the subaccounts and the fixed account?

By written request or other requests acceptable to us, you may
transfer all or part of the value of a subaccount to one or more of
the other subaccounts or to the fixed account.  The amount
transferred, however, must be at least: 1) $250; or 2) the total
value in the subaccount, if less.  We reserve the right to limit
such transfers to 5 per policy year.  We may suspend or modify this
transfer privilege at any time with the necessary approval of the
Securities and Exchange Commission.

You may also transfer from the fixed account to the subaccounts
once a year, but only on the policy anniversary or within 30 days<PAGE>
PAGE 31
after such policy anniversary.  If you make this transfer, you
cannot transfer from the subaccounts back into the fixed account
until the next policy anniversary.  If we receive your written
request within 30 days before the policy anniversary date, the
transfer from the fixed account to the subaccounts will be
effective on the anniversary date.  If we receive your written
request within 30 days after the policy anniversary date, the
transfer from the fixed account to the subaccounts will be
effective on the date we receive the request.  The minimum transfer
amount is $250 or the fixed account value minus indebtedness, if
less.  The maximum transfer amount is the fixed account value,
minus indebtedness.  We may suspend or modify this transfer
privilege at any time.<PAGE>
PAGE 32
                    Payment of Policy Proceeds

How are the proceeds paid?

We will pay the proceeds in a single sum unless a payment option
has been selected.  The date on which the proceeds are paid in a
lump sum or first placed under a payment option is the settlement
date.  All proceeds are payable at our home office.  We will pay
interest at a rate not less than 4% per year on single sum death
proceeds from the date of the last surviving insured's death to the
settlement date.

What are the payment options other than a single sum?

During an insured's lifetime, you may request in writing that we
pay the proceeds under one or more of the payment options shown
below, or that we change a prior election.  You may elect other
payment options not shown if we agree.

Unless we agree otherwise, however, a payment option may be
selected only if the payments are to be made to a natural person in
that person's own right.  Also, the amount of proceeds placed under
a payment option must be at least $5,000.

Option A - Interest Payments

We will pay interest on proceeds placed under this option at the
rate of 3% per year compounded annually.  We will make regular
interest payments at intervals and for a period that is agreeable
to both you and us. At the end of any payment interval, a
withdrawal of proceeds may be made in the amount of at least $100.
At any time, all of the proceeds that remain may be withdrawn or
placed under a different payment option approved by us.

Option B - Payments for a Specified Period

We will make monthly payments for a specified number of years.  The
amount of each monthly payment for each $1,000 placed under this
option is shown in the table below.  Monthly payment amounts for
years not shown will be furnished upon request.

                          Option B Table
                 Number                     Monthly
                 of Years                Payment/$1000
                   10                         9.61
                   15                         6.87
                   20                         5.51
                   25                         4.71
                   30                         4.18

Option C - Lifetime Income

We will make monthly payments for the life of the person (the
payee) who is to receive the income.  Payment will be guaranteed
for either 10, 15, or 20 years.  The amount of each monthly payment
for each $1,000 placed under this option will be based on our Table
of Settlement Rates in effect at the time of the first payment. The<PAGE>
PAGE 33
amounts will not be less than those shown in the table below for
the sex and Adjusted Age of the payee on the due date of the first
payment.  (See Adjusted Age Table.)

Monthly income amounts for any Adjusted Age not shown in the
following table will be furnished upon request.

Option C Table       M = Male   F = Female

Adjusted Age                Life Income per $1,000 with
   Payee                      Payments Guaranteed for  

                      10 years       15 years       20 years
                      M      F       M      F       M      F

     50               4.22   3.89    4.17   3.86    4.08   3.82
     55               4.62   4.22    4.53   4.18    4.39   4.11
     60               5.14   4.66    4.96   4.57    4.71   4.44
     65               5.81   5.22    5.46   5.05    5.02   4.79
     70               6.61   5.96    5.96   5.60    5.27   5.12
     75               7.49   6.89    6.38   6.14    5.42   5.35

Adjusted Age Table

The Adjusted Age is the age on the payee's nearest birthday, minus
an "adjustment" based on the year of birth of the payee as follows:

Calendar                             Calendar
Year of                              Year of
Payee's Birth    Adjustment          Payee's Birth   Adjustment  

Prior to 1920         0              1945 - 1949          6
1920 - 1924           1              1950 - 1959          7
1925 - 1929           2              1960 - 1969          8
1930 - 1934           3              1970 - 1979          9
1935 - 1939           4              1980 - 1989         10
1940 - 1944           5              After 1989          11

Will a supplemental contract be prepared if proceeds are placed
under a payment option?

If a payment option is requested, we will prepare an agreement
stating the terms under which payments will be made.  The agreement
will include statements about withdrawal value, if any, and to whom
remaining proceeds will be paid if the payee dies.

Can a beneficiary request a payment option?

After the last surviving insured's death but before any proceeds
are paid, the beneficiary may select a payment option by written
request to us.  You may provide, however, that the beneficiary will
not be permitted to change the payment option you have selected.
<PAGE>
PAGE 34
Are excess interest earnings payable by us?

On each anniversary of the settlement date, we will determine
excess interest, if any, on payment option deposits. Any such
excess interest will be paid under Option A or B.<PAGE>
PAGE 35
                  Four Year Term Insurance Rider

In consideration of the application for this rider and the payment
of the cost of insurance, this rider is made a part of the policy.
This rider is subject to all policy terms and provisions unless
this rider changes them.

What is the definition of insureds?

The persons whose lives are insured by the policy.

What is the amount of insurance?

The amount of insurance provided by this rider as shown under
Policy Data.

What benefit does this rider provide?

If we receive proof satisfactory to us that the last surviving
insured died during the first four policy years and while this
rider is in force, we will pay the amount of insurance as shown
under Policy Data for this rider to the beneficiary.

The beneficiary is named in the application for the policy.

Subject to the terms of the policy, the amount of insurance payable
by this rider to the beneficiary may be applied under one of the
payment options shown in the policy.

Is there a monthly deduction for the cost of this rider?

Yes.  While this rider is in force, a monthly deduction for the
cost of the rider is taken from the policy's value.  The amount of
the deduction is this rider's amount of insurance, as shown under
Policy Data, divided by 1,000 times the monthly cost of insurance
rate.

The monthly cost of insurance rate is the annual cost of insurance
rate described below divided by 12.

What is the cost of insurance rate?

The cost of insurance rate is the rate applied to this rider's
amount of insurance to determine the monthly deduction.  It is
based on each insured's sex, insurance age, risk classification and
the number of years the policy has been in force.

We may change the cost of insurance rates from time to time.  Any
change in the cost of insurance rate will apply to all individuals
of the same risk class as each of the insureds.  We will determine
cost of insurance rates based on our expectations as to future
mortality experience.  The cost of insurance rates will not exceed
the Guaranteed Maximum Annual Cost of Insurance Rates shown under
Policy Data.  These rates are based on the 1980 Commissioner's
Standard Ordinary Smoker or Non-smoker Mortality Tables, Age Last
Birthday.
<PAGE>
PAGE 36
Can you change the amount of insurance of this rider?

Yes. While this rider is in force you may decrease this rider's
amount of insurance once per policy year by written request. Such
request may only be made after the first policy year and is subject
to the following:

The decrease in face amount will be effective on the monthly date
on or next following our receipt of your written request.  The
amount of insurance that remains in force after a requested
decrease may not be less than $50,000.

Do policy changes affect this rider?

If the policy's specified amount is reduced for any reason, we will
reduce this rider's amount of insurance so that it does not exceed
the policy's new specified amount multiplied by 1.22.

If this rider's amount of insurance is reduced, the monthly
deduction for the cost of this rider will also be reduced.

When will coverage under this rider terminate?

This rider will terminate on the earliest of the following:

1.    the monthly date on or next following receipt of your written
      request for coverage to end; or

2.    the Expiration Date as shown under Policy Data; or

3.    the date the policy terminates.

Can this rider be reinstated if the policy has lapsed?

If the policy and this rider lapsed as provided in the policy's
grace period provision, this rider may be reinstated prior to the
Expiration Date if:

1.    this rider was in effect when the policy lapsed; and

2.    the policy is reinstated; and

3.    the requirements stated below are met.

In order to reinstate coverage for this rider, you must:

1.    provide evidence that both insureds remain insurable, or
      evidence for the last surviving insured and due proof that
      the first death occurred before the date of lapse; and

2.    pay a premium sufficient to keep this rider in force for 3
      months; and

3.    pay the monthly deductions that were not collected during the
      grace period.
<PAGE>
PAGE 37
The effective date of reinstatement will be the monthly date on or
next following the date we approve the application for
reinstatement.

What if the age or sex of an insured has been misstated?

If an insured's age or sex has been misstated, the amount payable
under this rider upon the last surviving insured's death will be
the amount of insurance, if any, that the rider cost for the policy
month during which the last surviving insured's death occurred,
would have purchased had the cost of the benefits provided under
the rider been calculated using the rider cost of insurance rates
for the correct age or sex.

When will this rider become incontestable?

The incontestable provision of the policy also applies to this
rider.

Is there a suicide exclusion?

The suicide exclusion provision of the policy also applies to this
rider.

What is the effective date of this rider?

The effective date of this rider is the policy date of the policy
unless a different date is shown under Policy Data.

IDS Life Insurance Company

/s/ William A. Stoltzmann

Secretary<PAGE>
PAGE 38
                     Policy Split Option Rider

This rider was issued in consideration of your application and
payment of its monthly deduction.  This rider is made a part of the
policy.  This rider is subject to all policy terms and provisions
unless this rider changes them.

What benefit does this rider provide?

While this rider is in effect, this policy may be exchanged without
evidence of insurability for two individual permanent plans of life
insurance we are then issuing, one on each of the insureds, upon
the occurrence of one of the following:

1.    a final divorce decree with respect to the marriage of the
      insureds is issued by a court of competent jurisdiction in
      the United States;
2.    the Federal Estate Tax law is changed resulting in removal of
      the unlimited marital deduction or reduced by at least 50%
      the level of the estate taxes payable on death.

What are the conditions for exchange?

The following conditions must be met in order to make the exchange:

1.    Both insureds must be living on the exchange date;

2.    You must request the exchange in writing within one year of
      the first enactment date of the Federal Estate Tax law change
      described above, if applicable;

3.    You must request the exchange in writing no sooner than six
      months after and no later than one year after the final
      divorce decree, if applicable.  You must provide us with a
      copy of the final divorce decree within this same time
      period.

4.    The owner of each new policy will be the owner of this policy
      unless otherwise specified in the applications and must have
      an insurable interest in the insured. If this policy is
      assigned, the assignee must consent to the exchange;

5.    This policy must be in force on the exchange date;

6.    We must receive payment of the first premium for each new
      policy on or before the Policy Date of each new policy.

When will the new policies become effective?

The new policies will become effective on the date we receive your
written request at our Home Office.

The New Policy

The initial death benefit of each new policy will be equal to one
half of the death benefit of this policy less one half of any
indebtedness on this policy on the date of the exchange.  One half<PAGE>
PAGE 39
of the policy value of this policy minus one half of any
indebtedness on this policy on the date of the exchange will be
applied as premium to each new policy.  Each new policy must be an
individual permanent plan of life insurance we are then issuing.
The new policy will be issued using the rates then in effect, the
insured's attained insurance age, and the same risk classification
as this policy.

What if the new policies are cancelled under the free-look
provision?

If you return either of the new policies under a free-look or right
to examine this policy provision, we will refund for each policy
returned an amount equal to one half of the cash surrender value of
this policy plus all additional premuums paid for the new policy.  

Can riders attached to this policy be added to the new policies?

No.  Riders attached to this policy will terminate on the effective
date of the split.

Is there a monthly deduction for the cost of this rider?

Yes.  While this rider is in force, a monthly deduction for the
cost of this rider is taken from the policy's value.  The amount of
the monthly deduction is the annual cost of insurance for this
rider, shown under Policy Data, divided by 12.

Do policy changes affect this rider?

If the policy's specified amount is changed for any reason, this
rider's monthly deduction will also be changed.

Is there a suicide exclusion and incontestable period?

Yes.  The suicide exclusion and incontestability provision of this
policy also apply to this rider.

When will this rider terminate?

This rider will terminate on the earliest of the following:

1.    the monthly date on or next following receipt of your written
      request for coverage to end; or

2.    the Expiration Date as shown under Policy Data; or

3.    the date the policy terminates.
<PAGE>
PAGE 40
What is the effective date of this rider?

The effective date of this rider is the policy date of the policy
unless a different date is shown under Policy Data.

IDS Life Insurance Company

/s/ William A. Stoltzmann

Secretary


Flexible Premium Survivorship 
Variable Life Insurance Policy

- Death benefit payable at last surviving insured's death. 
- Flexible premiums payable as provided herein. 
- Death Benefit Guarantees as described herein. 
- This policy is nonparticipating.  Dividends are not payable.



IDS Life Insurance Company
IDS Tower 10
Minneapolis, Minnesota 55440

<PAGE>
PAGE 1
ADDENDUM TO INVESTMENT MANAGEMENT AND SERVICES AGREEMENT

"Part Two:  COMPENSATION TO INVESTMENT MANAGER" paragraph (1) of
the Investment Management and Services Agreement between IDS Life
Series Fund, Inc. (the Fund) and IDS Life Insurance Company (IDS
Life) dated December 17, 1985, has been modified as follows.  All
other provisions of this Investment Management and Services
Agreement remain in full force and effect.

(1)  The Fund agrees to pay IDS Life, and IDS Life covenants and
agrees to accept from the Fund in full payment for all the services
furnished, and for the use of all facilities and equipment, and for
all expenses paid or reimbursed by IDS Life hereunder, a fee for
each calendar day of each year equal to the total of 1/365th
(1/366th in each leap year) of:

      .70 percent for the Equity Portfolio
      .70 percent for the Income Portfolio
      .70 percent for the Managed Portfolio
      .70 percent for the Government Securities Portfolio
      .95 percent for the International Equity Portfolio and
      .50 percent for the Money Market Portfolio

to be computed for each day on the basis of net assets as of the
close of business of the full business day two (2) business days
prior to the day for which the computation is being made.  In the
case of the suspension of the computation of net asset value, the
said fee for each day during such suspension shall be computed as
of the close of business on the last full business day on which the
net assets were computed.  As used herein, "net assets" as of the
close of a full business day shall include all transactions in
shares of the Fund recorded on the books of the Fund for that day.

IN WITNESS WHEREOF, the parties have executed the Addendum as of
the 28th day of October, 1994.

                                     IDS LIFE SERIES FUND, INC.

Attest: /s/ Colleen Curran           By: /s/ Richard W. Kling  
           Colleen Curran                    Richard W. Kling

Title:       Secretary               Title:  President         


                                     IDS LIFE INSURANCE COMPANY

Attest: /s/ Nancy Careaga            By:  /s/ William A. Stoltzmann
           Nancy Careaga                     William A. Stoltzmann

Title:  Assistant Secretary          Title:  Vice President        


<PAGE>
PAGE 1
ADDENDUM TO INVESTMENT ADVISORY AGREEMENT

The following provision is added to Section 6, Compensation to IDS,
of the Investment Advisory Agreement between IDS Life Insurance
Company (IDS Life) and IDS/American Express, Inc. (IDS) [now known
as IDS Financial Corporation] dated July 11, 1984.  All other
provisions of this Investment Advisory Agreement remain in full
force and effect.

6.  Compensation to IDS.  In addition to the fee for services
provided under the Investment Advisory Agreement described above,
IDS Life Series Fund, Inc. for the International Equity Portfolio
shall pay IDS life a fee for each calendar day of each year equal
to the total of 1/365th (1/366th in each leap year) of 0.25% of the
total net assets of the International Equity Portfolio for a total
of 0.50% of the net assets of the International Equity Portfolio. 
This additional 0.25% fee shall be paid on a monthly basis in cash
by IDS Life to IDS within five (5) business days after the last day
of each month.

(IN WITNESS WHEREOF, the parties have executed the Addendum as of
the 28th day of October, 1994.)


                                     IDS LIFE INSURANCE COMPANY

Attest:/s/ Nancy Careaga             By: /s/ Richard W. Kling      
           Nancy Careaga                     Richard W. Kling

Title:  Assistant Secretary          Title:  President             


                                     IDS FINANCIAL CORPORATION

Attest:/s/ Colleen Curran           By: /s/  William A. Stoltzmann
           Colleen Curran                    William A. Stoltzmann

Title:       Secretary               Title:  Vice President        

<PAGE>
PAGE 1
<TABLE><CAPTION>
<S>                                                                 <C>
IDS Life Insurance Company                                          Life and Disability
P.O. Box 499                                                        Income Insurance
Minneapolis, Minnesota  55440-0499                                  Application
-----------------------------------------------------------------------------------------------------------------------------------
Insured                                                      Other Insured Rider (OIR)/2nd Insured
Please provide both day and evening telephone numbers        Please provide both day and evening telephone numbers
Day (____) ____________  Evening (____) _____________        Day (____) ____________  Evening (____) _____________
Best time to call ___________  Day ___________ Evening       Best time to call ___________  Day ___________ Evening
-----------------------------------------------------------------------------------------------------------------------------------
Section A  Insured and Owner Information
1. Insured:  Is insured the owner?  __ Yes  __ No            Other Insured Rider (OIR)__  or 2nd Insured __ ?
                                                                 Is OIR/2nd Insured the owner?  __ Yes  __ No
   -----------------------------------------------------     ----------------------------------------------------------------------
   __ Mr.  __ Mrs.  __ Miss  __ Ms.                          __ Mr.  __ Mrs.  __ Miss  __ Ms.
   -----------------------------------------------------     ----------------------------------------------------------------------
   Insured's name (first)   (full middle)      (last)        OIR/2nd Insured's name (first)   (full middle)      (last)

   -----------------------------------------------------     ----------------------------------------------------------------------
   Home address (street)                                     Home address (street)

   -----------------------------------------------------     ----------------------------------------------------------------------
   City, State, Zip                                          City, State, Zip

   -----------------------------------------------------     ----------------------------------------------------------------------
   Social Security No.                                       Social Security No.

   -----------------------------------------------------     ----------------------------------------------------------------------
   Birthdate   Marital status   State of birth __ Male       Birthdate   Marital status   State of birth   __ Male
                                               __ Female                                                   __ Female
   -----------------------------------------------------     ----------------------------------------------------------------------
   Citizenship                                               Citizenship
   __ U.S.  __ Other ___________________________________     __ U.S.  __ Other _____________________________________
   -----------------------------------------------------     ----------------------------------------------------------------------
   Occupation                              Self-Employed     Occupation                              Self-Employed
                                           __ Yes  __ No                                             __ Yes  __ No
   -----------------------------------------------------     ----------------------------------------------------------------------
   Individual occ. income   Net worth   Household income     Individual income from occupation    Relationship to insured
   $                        $           $                    $                                     
   -----------------------------------------------------     ----------------------------------------------------------------------
   Employer name                                             Employer name

   -----------------------------------------------------     ----------------------------------------------------------------------
   Address (street)                                          Address (street)

   -----------------------------------------------------     ----------------------------------------------------------------------
   City, State, Zip                                          City, State, Zip
   -----------------------------------------------------     ----------------------------------------------------------------------

2. Owner (Complete if owner is different from Insured/OIR/2nd Insured)
   --------------------------------------------------------------------------------------------------------------------------------
   __ Mr.   __ Mrs.    Owner's name    (first)     (full middle)          (last)            Birthdate          __ Male
   __ Miss  __ Ms.                                                                                             __ Female
   --------------------------------------------------------------------------------------------------------------------------------
   Individual occ. income   Net worth   Household income   Bus. Tax ID, Taxpr. ID or Social Security No.   Relationship to insured
   $                        $           $
   --------------------------------------------------------------------------------------------------------------------------------
   Home address (street)                            (city)                      (state)                                      (zip)

   --------------------------------------------------------------------------------------------------------------------------------
   Employer name                      Address (street)                    (city)                         (state)             (zip)

   --------------------------------------------------------------------------------------------------------------------------------
3. Ownerships
   --------------------------------------------------------------------------------------------------------------------------------
   __ Individual

   __ Business:  __ Sole Proprietorship (03)     __ S Corporation (01)     __ Partnership (02)     __ C Corporation (01)
     Type of Business Insurance:  __ Buy/Sell       __ Business Debt Protection      __ Split Dollar    __ Key Person
                                  __ Other ____________________   __ Executive Bonus        __ Deferred Compensation
                                                                                               (nongovernmental)
   __ Trust:  __ Revocable     __Irrevocable     Name of Trust ____________________________________________________________________
              Date of Trust ________________  Trustee taxpayer identification number ______________________________________________
              Name and address of Trustee _________________________________________________________________________________________
   __ Other  ______________________________________________________________________________________________________________________
<PAGE>
PAGE 2
Section B  Life Insurance

1. Life Insurance Plan

   --------------------------------------------------------------------------------------------------------------------------------
   Insured Amount $                                          OIR Amount $

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

                                  (You must select either Option 1 or Option 2 for these plans)

    __ Life Protection Plus
    __ Variable Universal Life II                __ Death Benefit Option 1:  Initial death benefit is insured amount.
    __ Variable Universal Life II 350            __ Death Benefit Option 2:  Initial death benefit is insured amount plus
    __ Survivorship Variable Life (V2D)             accumulated cash value. Cost of insurance is greater than Option 1.
    __ 1-Year Term       __ 10-Year Term
    __ Whole Life
    __ Other ____________________________________________________________________________________________________________________

   --------------------------------------------------------------------------------------------------------------------------------
   Variable Universal Life & Survivorship Variable Life Allocations (complete financial suitability statement on signature page).
   --------------------------------------------------------------------------------------------------------------------------------
   Premium allocation: (premium amount to be directed to specific investment options within policy)
   Monthly deductions: (investment options within the policy from which the cost of insurance will be deducted)
   Owner's tax bracket _____________% (required for VUL & V2D policies)
   Investment        Premium    Monthly        Investment        Premium    Monthly        Investment        Premium    Monthly
   options          allocation deductions      options          allocation deductions      options          allocation deductions

   Fixed            _________% _________%      Equity           __________% _________%     2004 Trust       _________% _________%

   Income           _________% _________%      Money Market     __________% _________%     Other _________  _________% _________%

   Managed          _________% _________%      Gov't securities __________% _________%     Other _________  _________% _________%

   Int'l Equity     _________% _________%                                                                         100%       100%
   --------------------------------------------------------------------------------------------------------------------------------

2. Life Insurance Riders
   --------------------------------------------------------------------------------------------------------------------------------

    __ Other Insured Rider (OIR). Complete OIR in Section A and OIR Amount $ and Beneficiary in Section  B.
    __ Accelerated Benefit Rider for Terminal Illness
    __ Waiver of Premium or Waiver of Monthly Deduction
    __ Accidental Death Benefit of $_____________________________
    __ Four Term of $_______________ (V2D Only)
    __ Policy Split Option (V2D Only)

    __ Other ____________________________________________________________________________________________________________________
   --------------------------------------------------------------------------------------------------------------------------------

    __ Children's Insurance (CIR)   __________ Units
                                                       Complete FIR/CIR information below.
    __ Family Insurance (FIR)  __________ Units

   Children's Insurance Rider and Family Insurance Rider Information:

   A. __ Mr.   __ Mrs.  Spouse information (first, middle and last name)     Birthdate     State of birth     Height     Weight
      __ Miss  __ Ms.   __________________________________________________ _____________ __________________ __________ __________

   B. Name(s) of children to be covered by rider (must be under age 19 and unmarried)    Physical/mental abnormalities at birth?
      Name (first)     (full middle)     (last)            Birthdate           Sex                      (if yes, explain here)
      ______________________________________________________________________________   __ Yes  __ No   __________________________
      ______________________________________________________________________________   __ Yes  __ No   __________________________
      ______________________________________________________________________________   __ Yes  __ No   __________________________

   C. Has anyone listed above received treatment for any disease, physical or mental condition in the past five years?
      __ Yes  __ No

   D. Is this insurance intended to replace any existing insurance and/or annuity?  __ Yes  __ No

   E. If yes to C or D above, explain here ______________________________________________________________________________________
      ___________________________________________________________________________________________________________________________

   F. Are there any children under the age of 19 and unmarried not listed above   __ Yes  __ No
      If yes, list name, birthdate and reason for exclusion _____________________________________________________________________
      ___________________________________________________________________________________________________________________________
<PAGE>
PAGE 3
Section B  Life Insurance (continued)

3. Life Insurance Premiums

   --------------------------------------------------------------------------------------------------------------------------------
   Amount of scheduled/      Amount paid with          Lump-sum amount to be          Premium Payment Frequency
   annual premiums           application               paid on delivery of policy     __ Monthly  __ Quarterly
   $________________________ $________________________ $_____________________________ __ Semiannually  __ Annually
   --------------------------------------------------------------------------------------------------------------------------------
   Method of Payment:  __ New Bank Authorization    __ Add to Existing Bank Authorization account no. ___________________________
                       (BA can be set up for monthly or quarterly frequencies only.  Complete attached BA form.)

                       __ Direct Billing    __ Other ____________________________________________________________________________
   --------------------------------------------------------------------------------------------------------------------------------

4. Life Insurance Beneficiary (for Survivorship Variable Life, complete b. below)

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

a. Option A. Beneficiary is: Insured's designated spouse, if living, otherwise the beneficiaries are the living lawful children
             of the Insured and they will receive equal shares of the proceeds.

   Option B. Beneficiary is: Insured's designated spouse, if living, otherwise, the beneficiaries are the living lawful children
             of the Insured and they will receive equal shares of the proceeds; provided, however, that if a child of the Insured
             has died before the Insured, the share which the child would have received if he/she survived the Insured will be
             paid to his/her living lawful children in equal shares.

   Option C. Other designation.

                             Insured:                                      OIR:

   __ Option A           __ Option B           __ Option C           __ Option A           __ Option B           __ Option C

   For Option A or B:                                                   For Option A or B:

   Insured's spouse's full name ______________________________________  OIR's spouse's full name ________________________________

   Option C: Other designation _______________________________________  Option C: Other designation _____________________________

   ___________________________________________________________________  _________________________________________________________

   ___________________________________________________________________  _________________________________________________________

   Relationship to Insured ___________________________________________  Relationship to OIR ____________________________________

b. Survivorship Variable Life Beneficiary designation ___________________________________________________________________________

   ______________________________________________________________________________________________________________________________

   ______________________________________________________________________________________________________________________________

   Relationship to Insureds _____________________________________________________________________________________________________

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

5. Juvenile Insurance

   --------------------------------------------------------------------------------------------------------------------------------
   COMPLETE IF INSURED IS UNDER AGE 15
   --------------------------------------------------------------------------------------------------------------------------------
   Did the representative see this child?    Is there similar insurance in force or applied for on all brothers and sisters?

    __ Yes  __ No                            __ Yes  __ No     If not, why? _____________________________________________________

   Amount of life insurance already in force on the person responsible for child's primary support $_____________________________


   X _______________________________________________   X ____________________________________________    ________________________
     Signature of Parent or Legal Guardian               Signature of Witness                            Date

   --------------------------------------------------------------------------------------------------------------------------------
<PAGE>
PAGE 4
Section C  Disability Income and Business Expense Protection Insurance

1. Disability Income Insurance Plan

   --------------------------------------------------------------------------------------------------------------------------------
   Monthly Benefit                          Insured's Occupation Class                         Waiting Period

   $                                        __ 1A  __ 2A  __ 3A                                __ 30 days   __ 60 days   __ 90 days
                                            __ 4A  __ 5A                                       __ 180 days  __ 365 days
   --------------------------------------------------------------------------------------------------------------------------------
   Duration of Benefit                            Multiple Case Discount                       Premium Pattern

   __ 1 yr  __ 3 yrs  __ 5 yrs  __ to age 65      __ Yes  __ No                                __ Level  __ Step Rate
   --------------------------------------------------------------------------------------------------------------------------------
   Employer Plan Coverage Unisex Rates  (Two participants and employer billing required)   __ Yes  __ No
   --------------------------------------------------------------------------------------------------------------------------------
   Disability Provision    Occupation Classes 1A, 2A & 3A:  __ 2 Years Occupation Protection

   Occupation Classes 4A & 5A:  __ 5 Years Occupation Protection  __ Gradual Recovery Benefits
                                __ Gradual Recovery Benefits and Occupation Protection Option
   --------------------------------------------------------------------------------------------------------------------------------



2. Disability Underwriting Information

   --------------------------------------------------------------------------------------------------------------------------------
   A. Complete description of job duties.  Years of service __________  Number of hours worked per week __________

   ______________________________________________________________________________________________________________________________

   ______________________________________________________________________________________________________________________________

   ______________________________________________________________________________________________________________________________

   ______________________________________________________________________________________________________________________________

   ______________________________________________________________________________________________________________________________

   ______________________________________________________________________________________________________________________________

      If self-employed:  1. Date business began ___________________________  Number of employees ______________
                         2. What % of duties are supervisory? ____________________________

   B. Any contemplated change in occupation?  __ Yes  __ No  If yes, explain ____________________________________________________

   C. Previous occupation if changed in the past five years _____________________________________________________________________

      ___________________________________________________________________________________________________________________________

   D. Amount of unearned income $_______________________________   Source _______________________________________________________

   E. Is the Insured a member of a State, Public, or Federal Retirement System?  __ Yes  __ No

      If yes, which one? _____________________________________________________

   F. Does the insured have any Disability Income Insurance through his/her employer?

      __ Yes  __ No  If yes, complete questions a-c below:

      a. Short-term at $_____________ per month for ______ months and ______ day waiting period
      b. Long-term at $_____________ per month for ______ years and ______ day waiting period
      c. Is the group disability integrated with Social Security  __ Yes  __ No 

   G. Will the Insured's employer be paying the premiums for the IDS Life Disability Insurance?     __ Yes  __ No

   H. Is the Insured eligible for benefits from a required state Cash Sickness disability program?  __ Yes  __ No

   --------------------------------------------------------------------------------------------------------------------------------
<PAGE>
PAGE 5
Section C  Disability Income and Business Expense Protection Insurance (continued)

3. Disability Income Insurance Riders

   --------------------------------------------------------------------------------------------------------------------------------
    __  Other ___________________________________________________________________________________________________________________

    __  Social Benefits Rider $____________ per month with waiting period of ______ days.

    __  Supplemental DI $____________ per month for ______ months and ______ day waiting period

    __  Cost-of-Living Maximum ____________% (classes 2A, 3A, 4A and 5A)

    __  Future Purchase Option $____________ Pool Amount

    __  Hospital Indemnity $____________ per month
   --------------------------------------------------------------------------------------------------------------------------------
    __  Accidental Death and Dismemberment (AD&D) $_______________   Complete AD&D Beneficiary information below

   AD&D Beneficiary

    __  Option A  __ Option B      Insured's spouse's full name _________________________________________________________________

    __  Option C  Other designation _____________________________________________________________________________________________
                _________________________________________________________________________________________________________________
                _________________________________________________________________________________________________________________
                _________________________________________________________________________________________________________________
                _________________________________________________________________________________________________________________
                _________________________________________________________________________________________________________________
                _________________________________________________________________________________________________________________
       Relationship to Insured __________________________________________________________________________________________________
   --------------------------------------------------------------------------------------------------------------------------------

4. Disability Income Insurance Premiums

   Annual premiums            Amount paid with            Amount to be paid on            Premium payment Frequency
                              application                 delivery of policy              __ Monthly  __ Quarterly

   $_________________________ $__________________________ $_____________________________  __ Semiannually  __ Annually

   Method of Payment:  __ New Bank Authorization  __ Add to Existing Bank Authorization account no. _____________________________
                       (BA can be set up for monthly or quarterly frequencies only.  Complete attached BA form.)

                       __ Direct Billing  __ Other ______________________________________________________________________________

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

-----------------------------------------------------------------------------------------------------------------------------------
Business Expense Protection Insurance
-----------------------------------------------------------------------------------------------------------------------------------

1. Business Expense Protection Insurance Plan

   (Cannot be applied for without personal Disability Income Protection in force or applied for.)
   Complete Disability Underwriting Information Section

   --------------------------------------------------------------------------------------------------------------------------------
   Monthly Benefit                       Insured's Occupation Class            Waiting Period                   Benefit Pattern
   $___________________________________  __ 3A  __ 4A  __ 5A                   __ 30 days     __ 60 days        __ Level
    Submit Form 34591                                                                __ 90 days                       __ Increasing
    (Available on DI Proposal System)
   Multiple Case Discount  __ Yes  __ No
   --------------------------------------------------------------------------------------------------------------------------------

2. Business Expense Protection Insurance Premiums

   --------------------------------------------------------------------------------------------------------------------------------
   Annual premiums              Amount paid with               Amount to be paid on               Premium Payment Frequency
                                application                    delivery of policy                 __ Monthly  __ Quarterly
   $___________________________ $_____________________________ $_________________________________ __ Semiannually  __ Annually

   Method of Payment:  __ New Bank Authorization  __ Add to Existing Bank Authorization account no. _____________________________
                       (BA can be set up for monthly or quarterly frequencies only.  Complete attached BA form.)

                       __ Direct Billing  __ Other ______________________________________________________________________________
<PAGE>
PAGE 6
Section D  Medical History

-----------------------------------------------------------     -------------------------------------------------------------------
Insured:                                                        Other Insured Rider (OIR)/2nd Insured:
-----------------------------------------------------------     -------------------------------------------------------------------
Doctor or Clinic                                                Doctor or Clinic

1.                                                              1.
-----------------------------------------------------------     -------------------------------------------------------------------
Patient number                 Phone number                     Patient number                 Phone number

-----------------------------------------------------------     -------------------------------------------------------------------
Address                        City     State  Zip              Address                        City     State  Zip

-----------------------------------------------------------     -------------------------------------------------------------------
Date last seen         Reason last seen                         Date last seen         Reason last seen

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

2. Height __________   Weight _________________                 2. Height __________   Weight _________________

3. Have you ever had, or been told you had, consulted           3. Have you ever had, or been told you had, consulted
   with, been tested for or treated by a doctor or medical         with, been tested for or treated by a doctor or medical
   practitioner for the following: (circle disorder for            practitioner for the following: (circle disorder for
   "Yes" answers)                                                  "Yes" answers)

   A. Cancer or tumor, unusual fatigue, disorder of the            A. Cancer or tumor, unusual fatigue, disorder of the
      muscles, bones, neck, back, joints, skin, liver, kidneys,       muscles, bones, neck, back, joints, skin, liver, kidneys,
      urinary tract, digestive, or reproductive system?               urinary tract, digestive, or reproductive system?
      __ Yes  __ No                                                  __ Yes  __ No
      Date of last consultation, test or treatment ___________        Date of last consultation, test or treatment ___________

   B. Chest pain, disorder of the heart, circulation, high         B. Chest pain, disorder of the heart, circulation, high
      blood pressure, lung or breathing disorder, diabetes,           blood pressure, lung or breathing disorder, diabetes,
      epilepsy, stroke, loss of consciousness, paralysis,             epilepsy, stroke, loss of consciousness, paralysis,
      brain or nervous system?  __ Yes  __ No                         brain or nervous system?  __ Yes  __ No
      Date of last consultation, test or treatment ___________        Date of last consultation, test or treatment ___________

   C. Mental illness, depression, emotional disorder, alcohol      C. Mental illness, depression, emotional disorder, alcohol
      or drug/substance abuse?  __ Yes  __ No                         or drug/substance abuse?  __ Yes  __ No
      Date of last consultation, test or treatment ___________        Date of last consultation, test or treatment ___________

4. Have you ever been diagnosed or received treatment by        4. Have you ever been diagnosed or received treatment by
   a member of the medical profession for AIDS (Acquired           a member of the medical profession for AIDS (Acquired
   Immune Deficiency Syndrome) or ARC (AIDS-Related                Immune Deficiency Syndrome) or ARC (AIDS-Related
   Complex?)  __ Yes  __ No                                        Complex?)  __ Yes  __ No
   Date of last consultation, test or treatment ______________        Date of last consultation, test or treatment ___________

5. Within the past five years have you stayed overnight in a    5. Within the past five years have you stayed overnight in a
   hospital or gone to an emergency room for any illness,          hospital or gone to an emergency room for any illness,
   or injury, been to a medical clinic, therapist or doctor,       or injury, been to a medical clinic, therapist or doctor,
   or presently have a physical impairment or illness not          or presently have a physical impairment or illness not
   listed above?  __ Yes  __ No                                    listed above?  __ Yes  __ No
   Date of last consultation, test or treatment                    Date of last consultation, test or treatment
   If yes, give reason:                                            If yes, give reason:
   _________________________________________________________       _________________________________________________________
   _________________________________________________________       _________________________________________________________
   _________________________________________________________       _________________________________________________________

6. Have you smoked cigarettes in the past 12 months?            6. Have you smoked cigarettes in the past 12 months?
   __ Yes  __ No                                                  __ Yes  __ No
   Have you ever smoked cigarettes?  __ Yes  __ No                 Have you ever smoked cigarettes?  __ Yes  __ No
   Date ceased smoking cigarettes __________________________       Date ceased smoking cigarettes __________________________
   Have you used tobacco in any other form?  __ Yes  __ No         Have you used tobacco in any other form?  __ Yes  __ No
   If yes, what is used? ___________________________________       If yes, what is used? ___________________________________
   What amount? ____________________________________________       What amount? ____________________________________________
   Date last used? _________________________________________       Date last used? _________________________________________<PAGE>
PAGE 7
Section E  Underwriting Information

-------------------------------------------------------------     -----------------------------------------------------------------
Insured                                                           Other Insured Rider (OIR)/2nd Insured:

1. Do you have any current plans to travel outside of the         Do you have ny current plans to travel outside the
   United States?:  __ Yes  __ No                                 United States?:  __ Yes  __ No
   If yes, where ____________________________________________     If yes, where __________________________________________
   For how long ______________________ Reason _______________     For how long ______________________ Reason _____________
   __________________________________________________________     ________________________________________________________
   __________________________________________________________     ________________________________________________________

2. During the past five years have you:                           During the past five years have you?

   A. Flown, or do you contemplate flying as a pilot, student     A. Flown, or do you contemplate flying as a pilot, student
      pilot or crew member?  __ Yes  __ No                           pilot or crew member?  __ Yes  __ No

   B. Participated in or do you contemplate participating in      B. Participated in or do you contemplate participating in
      motorcycle riding, racing (automobile, snowmobile,             motorcycle riding, racing (automobile, snowmobile,
      motorcycle, boat), skin/scuba diving, skydiving, hang-         motorcycle, boat), skin/scuba diving, skydiving, hang-
      gliding, or other similar activities?                          gliding, or other similar activities?
      __ Yes  __ No                                                  __ Yes  __ No
      If yes, what activity? ________________________________        If yes, what activity? ________________________________

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


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

Insured: 

3. Have you ever had an application for insurance declined, postponed or modified in any way?  __ Yes  __ No
   If yes, provide date ___________________ Company name _________________________________________________________________________
   Reason ________________________________________________________________________________________________________________________

4. Will this insurance replace any existing insurance or annuity policies?  __ Yes  __ No
If replacing an existing IDS Life policy, the cash value should be: __ rolled to the new IDS Life policy __ returned to the client

5. List any annuities, or life or disability income insurance currently in force or applied for:

                      Plan                           Policy       Ins. amount/     D.I. yrs        ADB           Will this
   Company name       type       Policy number        date         mo. income       payable       amount       be replaced?*

   _________________ ______ _____________________ ___________ $_________________ _____________ $___________   __ Yes   __ No

   _________________ ______ _____________________ ___________ $_________________ _____________ $___________   __ Yes   __ No

   _________________ ______ _____________________ ___________ $_________________ _____________ $___________   __ Yes   __ No
 *If the insurance applied for will replace any existing insurance, Submit replacement form(s) if required.

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


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

Other Insured Rider (OIR)/2nd Insured:

3. Have you ever had an application for insurance declined, postponed or modified in any way?  __ Yes  __ No
   If yes, provide date ____________  Company name ______________________________________________________________________________
   Reason _______________________________________________________________________________________________________________________

4. Will this insurance replace any existing insurance or annuity policies?  __ Yes  __ No
   If replacing an existing IDS Life policy, the cash value should be: __ rolled to the new IDS Life policy __ returned to the
   client

5. List any annuities, or life or disability income insurance currently in force or applied for:

                      Plan                           Policy       Ins. amount/     D.I. yrs        ADB           Will this
   Company name       type       Policy number        date         mo. income       payable       amount       be replaced?*

   _________________ ______ _____________________ ___________ $_________________ _____________ $___________   __ Yes   __ No

   _________________ ______ _____________________ ___________ $_________________ _____________ $___________   __ Yes   __ No

   _________________ ______ _____________________ ___________ $_________________ _____________ $___________   __ Yes   __ No
 *If the insurance applied for will replace any existing insurance, Submit replacement form(s) if required.
<PAGE>
PAGE 8
IDS Life Insurance Company                                          Life and Disability
P.O. Box 499                                                        Income Insurance
Minneapolis, Minnesota  55440-0499                                  Application


Agreement and Signature
-----------------------------------------------------------------------------------------------------------------------------------

Agreement

By signing this application, you acknowledge all the following terms and conditions.

    Adequate information. You have received the IDS Life's Client Information Practices, and you have read and
    understood it.

    When coverage begins. You agree that an Insured for life or disability insurance will be covered prior to policy delivery
    only when all of the following requirements have been met:

    The owner has paid the full first premium, according to the mode of premium payment selected, for all insurance
    applied for in this application (any check or draft for that payment must be honored by the bank); and

    The Insured has submitted all medical and other information required by the company's written underwriting rules; and

    The Insured is insurable on the Effective Date, as defined below, under the company's underwriting rules, for the plan
    and amount of coverage at the rate applied for with no modification. "Effective Date" as used herein means the later of:
    (a) the date of this application; or (b) the date of completion of all medical examinations and other information required
    by the company's written underwriting rules.

    In cases where the Insured is not insurable for the plan or the amount or at the rate applied for, coverage begins if and
    when the company includes that person under a policy accepted by the owner.

    For disability coverage, all disability policies specified to be discontinued in this application must also be discontinued
    before coverage will begin.  (This limitation is subject to the incontestability provision in the policy.)

    Amount of coverage. Before the policies are delivered, the amount of coverage on each Insured will be the total
    requested for that person, up to a maximum of $150,000.

    Company's responsibilities.  You understand that:
    Only the officers of the company have the authority to decide on insurability and risk classification and to bind the
    company to insure a proposed Insured.  The officers of the company are the President, Vice President, Secretary and
    Assistant Secretary;

    If a policy does not go into effect, the company's sole liability will be to refund any premium paid, plus interest if
    required by law;

    No change in or waiver of anything in this application or alteration of an insurance policy is binding unless it is in
    writing and signed by an officer of the company; and

    By accepting a policy, the owner ratifies any changes entered at any time on the Home Office Endorsement form
    attached to the policy.  However, the owner must sign a separate written document for any change in type of plan,
    amount, benefits or Insured's risk classification.  (Not applicable in New Jersey and West Virginia.)

    Any insurance provided by this agreement will be subject to the conditions and terms of the policy applied for.

    Release of Information. You understand and agree that the company will use and release information about you as
    described in the attached IDS Life's Client Information Practices.  You may inform us not to use information for certain
    marketing purposes described in IDS Life's Client Information Practices.

    Qualified Plans only. You certify that the plan under Ownership of the insurance application is qualified under
    Section 401(a) of the United States Internal Revenue Code.  This policy will be issued based on representations by
    you that the Plan is qualified.

    Declaration

    You declare that each of the answers made in this application is true and complete to the best of your knowledge and
    belief and will be a basis for any policy issued.  You also acknowledge that you have received a copy of this agreement
    and receipt for any premium paid with this application.

    Certification

    You certify, under the penalties of perjury as required by Form W-9 of the Internal Revenue Service, that the names,
    addresses and Social Security (taxpayer ID) numbers provided in this application are true, correct and complete.

<PAGE>
PAGE 9
                                                     Client Copy
                                                     ------------
Financial Suitability Statement

Variable Universal Life/Survivorship Variable Life.  If you have applied for this type of insurance, check each of the
  following to acknowledge that you have received and read them:

__ Adequate information. You have received the current prospectuses for the policy applied for and any funds involved.

__ Purpose. You agree that this variable type of insurance is in accord with your insurance and financial objectives.
   __ You understand that there can be no assurance that such objectives will be achieved.
   __ Your risk tolerance for investment is:   __ Low   __ Medium   __ High
   __ Your specific long-term goals and objectives are:
      __ Protection   __ Tax Deferral   __ Capital Appreciation   __ Stability of Principal

__ Variable values. The amount of Death Benefit and Policy Value can both increase and decrease; however, the
   Death Benefit will never be less than any Guaranteed Minimum Death Benefit.

__ Fees and charges. The fees and charges (including possible surrender charges) have been explained to you and are
   also explained in detail in the policy.

Life Protection Plus/Universal Life Insurance. If you have applied for this type of insurance, you acknowledge that you
  have been informed that (1) the company may periodically change the current interest rate being credited on cash values,
  and (2) that surrender charges may apply in certain circumstances.

Authorization to Obtain Information -- IDS Life Insurance Company
  You authorize any physician, medical practitioner, hospital, other medical facility, the Medical Information Bureau,
  employer, and consumer reporting agency having medical and other information about you and your minor children to
  give that information to the company or its reinsurer.  You understand that the company will use this information to
  determine eligibility for insurance and benefits.  You acknowledge that your medical records, including any alcohol or drug
  abuse information, may be protected by the Federal Alcohol and Drug Abuse Regulation 42 CFR Part 2.
  You authorize the company to obtain investigative consumer reports on you and your minor children.  You understand that
  you have the right to request a personal interview if an investigative consumer report is obtained.
  You agree that a photographic copy of this authorization will be as valid as the original.
  You agree that this authorization will be valid for two and one-half years from the date shown below.
  You acknowledge that you have received a copy of this authorization.

Signatures (Insureds under age 15 need not sign.)

Insured (base plan)  X____________________________________    OIR/2nd Insured X_________________________________________________
         FIR Spouse  X____________________________________    OIR Insured X_____________________________________________________

Owner's signature (omit if owner already signed as an insured)    X_____________________________________________________________

Signed on (date) ____ - ____ - ____, (state) __________, at (city), X___________________________________________________________

Receipt
-----------------------------------------------------------------------------------------------------------------------------------
All checks must be completed in full and be made payable to the company (not to the representative).

Received from ______________________________________________ the sum of $______________________________ with this application.

__ No money paid with this application.

Representative's Report
-----------------------------------------------------------------------------------------------------------------------------------

Is Insured related to representative?  __ Yes   __ No  If yes, give relationship ________________________________________________
You certify that you personally requested the information in this application and witnessed its signing and received any
money that was paid.  You also certify that you truly and accurately recorded on this application the information supplied by
the applicant.  You are not aware of anything detrimental to the risk that is not recorded in this application.

To the best of your knowledge and belief this application  __ does  __ does not involve replacement of existing insurance
or annuities.

Representative's signature X___________________________________________________________   No. _______________  DO _______________

Compensation _____________________________%  Phone (________) ________ - ________________________  Team ID ______________________

Representative's name (print) ____________________________________________________________________________

Joint Representative's signature X___________________________________________________  No. _______________

Compensation _____________________________%  Phone (________) ________ - ________________________  Team ID ______________________

Compensation percentages must equal 100%.

Indicate Fax No. (________) ________ - ________________________  If you want to receive status information via FAX
                                                                 instead of Telememo.
31445 A
</TABLE>
<PAGE>
PAGE 1
                   IDS LIFE INSURANCE COMPANY'S
       DESCRIPTION OF TRANSFER AND REDEMPTION PROCEDURES AND
          METHOD OF CONVERSION TO FIXED BENEFIT POLICIES

     This document sets forth, as required by Rule
6e-3(T)(b)(12)(iii), the administrative procedures that will be
followed by IDS Life Insurance Company ("IDS Life") in connection
with the issuance of its flexible premium survivorship variable
life insurance policy ("Policy"), the transfer of assets held
thereunder, and the redemption by Policyowners of their interests
in said policies.  The document also describes the method that IDS
Life will use when a Policy is exchanged for a fixed benefit
insurance policy pursuant to Rule 6e-3(T)(b)(13)(v)(B).

                TRANSFER AND REDEMPTION PROCEDURES

I.   Purchase and Related Transactions

     A.  Premium Schedules and Underwriting Standards

     This Policy is a flexible premium policy.  The Policyowner has
flexibility, subject to certain restrictions, in determining the
amount and frequency of premium payments.  At the time of
application, the Policyowner will determine a Scheduled Premium. 
The Scheduled Premium is a level amount at a fixed interval of
time.  However, the Policyowner can change the Scheduled Premium,
skip premium payments or make additional premium payments. 
Generally, the Policyowner may, subject to certain restrictions,
make premium payments in any amount and at any frequency.

     Failure to pay a Scheduled Premium will not itself cause a
Policy to lapse.  Payment of Scheduled Premiums, however, will not
guarantee that it will remain in force.  (For further information
about when a Policy will lapse, see page 5.)

     Each month, a deduction is made from the Policy Value for the
cost of insurance, policy fee and optional benefits.  This
deduction is based on the age, sex and risk classification of each
Insured and the duration of the Policy.

     The Policies will be offered and sold pursuant to established
underwriting standards, and in accordance with state insurance
laws, which prohibit unfair discrimination among Policyowners, but
recognize that insurance costs must be based upon factors such as
age, sex, health or occupation.

     B.  Application and Initial Premium Processing

     Upon receipt of a completed application, IDS Life will follow
certain insurance underwriting (i.e., evaluation of risks)
procedures designed to determine whether the proposed Insureds are
insurable.  This process may involve such verification procedures
as medical examinations and may require that further information be
provided by the proposed Insureds before a determination can be
made.  A Policy will not be issued and consequently a Policy Date
established, until this underwriting procedure has been completed.
<PAGE>
PAGE 2
     If a premium is submitted with the Policy application,
insurance coverage will begin immediately if the Insureds are
insurable under a conditional insurance agreement.  Otherwise,
insurance coverage will not begin until coverage is approved by IDS
Life.

     If a premium is not paid with the application, insurance
coverage will begin on the date the premium is received, if the
Insureds are insurable under a conditional insurance agreement, or
on the later of the date the premium is received or the date IDS
Life approves coverage if the Insureds are not insurable under a
conditional insurance agreement.

     C.  Premium Allocation

     In the application for a Policy, the Policyowner can allocate
premiums to the Fixed Account and/or the subaccounts.  Until the
policy date, the premiums received by IDS Life are held in IDS
Life's Fixed Account and interest at the current Fixed Account rate
is credited on the net premiums.  As of the policy date, the net
premiums plus interest accrued thereon will be allocated to the
Fixed Account and/or the subaccounts in accordance with the
allocation instructions received from the Policyowner in the
application.  Future net premiums will be allocated to the Fixed
Account and/or the subaccounts, in accordance with the application
allocation instructions unless the Policyowner changes the
allocation instructions by written request.  Net premiums received
after the date IDS Life receives the new instructions, will be
allocated to the Fixed Account and/or the subaccounts, based on the
new allocation instructions.

     D.  Repayment of Loan

     A loan made under the policy will be subject to an interest
rate of 6% per year.  IDS Life expects to reduce the loan interest
rate after the 10th policy anniversary to 4% per year.  The
Policyowner can at any time make a loan repayment which must be at
least $50 or 100% of the amount of the outstanding loan, if less.

     When a loan is made, any loan taken from the subaccounts will
be transferred to the Fixed Account.  The portion of the Fixed
Account Value which equals indebtedness will be credited with
interest at a rate of 4%.

     All loan repayments will be allocated to the Fixed Account
and/or the subaccounts, using the premium allocation percentages in
effect at the time of payment unless the Policyowner specifies that
the loan repayment is to be allocated in a different manner.

II.  Transfer Among the Subaccounts and the Fixed Account

     The Policy currently has a Fixed Account and six subaccounts. 
The subaccounts invest in portfolios of IDS Life Series Fund, Inc. 
<PAGE>
PAGE 3
     Except as noted in the next paragraph, the Policyowner may
transfer at any time all or part of the value of a subaccount to
other subaccounts, or to the Fixed Account by written request or
other requests acceptable to IDS Life.  Each transfer must be for a
minimum of $250 or, if the value of the subaccount is less than
$250, the value of the subaccount.  The transfer will take effect
on the date the request is received by IDS Life.  IDS Life reserves
the right to limit transfers to five each policy year.

     The Policyowner may transfer from the Fixed Account to the
subaccounts once a year but only on a policy anniversary or within
30 days after such policy anniversary.  If such a transfer is made,
the Policyowner cannot transfer from the subaccounts back to the
Fixed Account until the next policy anniversary.  If IDS Life
receives a request within 30 days before a policy anniversary date,
the transfer will be effective on the anniversary date.  If IDS
Life receives a request within 30 days after a policy anniversary
date, the transfer will be effective on the date the request is
received by IDS Life.  The minimum transfer amount is $250 or the
Fixed Account Value less indebtedness, if less.  The maximum
transfer amount is the Fixed Account Value less indebtedness.

     The Policyowner may request a transfer by calling IDS Life. 
IDS Life has the authority to honor any telephone transfer request
believed to be authentic.  IDS Life is not responsible for
determining the authenticity of such calls.  A transfer request
received before 3 p.m. Central time (which is 4 p.m. New York time)
will be processed the same day.  If a call or written request is
received after 3 p.m. Central time, the request will be processed
the following business day.

     Automated transfers are also available.  Automated transfers
of at least $50 may be requested monthly, quarterly, semiannually
or annually.  Only one automated transfer arrangement may be in
effect at any time.  Policy values may be transferred to one or
more subaccounts and the Fixed Account but can be transferred from
only one account. Automated transfers from the Fixed Account may
not exceed an amount that, if continued, would deplete the Fixed
Account within 12 months.  If transfers from the Fixed Account to
one or more of the subaccounts are made, transfers from the
subaccounts back to the Fixed Account will not be allowed until the
next policy anniversary.

III.  "Redemption" Procedures:  Surrender and Related Transactions

     A.  Surrender for Cash Value

     At any time before the death of the last surviving Insured,
the Policyowner may completely surrender the Policy by written
request.  Any surrender payment from the subaccounts will be made
within seven days after IDS Life receives the written request,
unless payment is postponed pursuant to the relevant provisions of
the Investment Company Act of 1940.  Any surrender payment from the
Fixed Account may be postponed for up to 6 months.  If IDS Life
postpones payment more than 30 days, interest at an annual rate of <PAGE>
PAGE 4
3 percent will be paid on the amount surrendered for the period of
postponement.  The surrender payment will equal the Policyowner's
Policy Value minus Indebtedness and, during the first fifteen
policy years, the Surrender Charge.

     After the first policy year, the Policyowner may also request
a partial surrender up to 85 percent of the Policy's Cash Surrender
Value by written request or by calling IDS Life.  IDS Life has the
authority to honor any telephone surrender request believed to be
authentic.  IDS Life is not responsible for determining the
authenticity of such calls.  A surrender request received before
3 p.m. Central time (which is 4 p.m. New York time) will be
processed the same day.  If the call or written request is received
after 3 p.m., the request will be processed the following business
day.  A fee of $25, but not exceeding 2 percent of the amount
surrendered is assessed for each partial surrender.  The amount of
any partial surrender must be at least $500.

     B.  Benefit Claims

     As long as the Policy remains in force, IDS Life will pay a
death benefit to the named beneficiary after receipt of due proof
of death of the last surviving Insured unless the Policy is
contested.  The amount of the death benefit will be determined as
of the date of death of the last surviving Insured.  The death
benefit proceeds will include interest from that date of death
until the date of payment.  The death benefit proceeds payable will
be reduced by any Loan Balance.

     Prior to the youngest Insured's attained insurance age 100,the
Policy provides two Death Benefit Options - Option 1 (a level
amount option) and Option 2 (a variable amount option).  The
Policyowner chooses which option applies.

     Under Option 1, the death benefit is the greater of

          1)  the Specified Amount; or

          2)  the applicable percentage of the Policy Value.

     Under Option 2, the death benefit is the greater of

          1)  the Policy Value plus the Specified Amount; or

          2)  the applicable percentage of the Policy Value.

     In lieu of payment of the death benefit in a single sum, an
election may be made to apply all or a portion of the proceeds
under one of the fixed benefit settlement options described in the
Policy.  The election may be made by the Policyowner during the
Insured's lifetime.  The beneficiary may make an election unless
the Policyowner has already done so.  The fixed benefit settlement
options are subject to the restrictions and limitations set forth
in the policy.
<PAGE>
PAGE 5
     On or after the youngest Insured's attained insurance age 100,
the proceeds payable upon the death of the last surviving Insured
will be the Policy's Cash Surrender Value.

     C.  Policy Lapsation

     A lapse will occur if, on a monthly date, the Cash Surrender
Value is less than the monthly deduction for the policy month
following such monthly date.  If lapse is going to occur, IDS Life
will notify the Policyowner, and the Policyowner will have a 61 day
grace period to make a premium payment so that the next three
monthly deductions can be made.

     The Death Benefit Guarantee to Age 85 provision provides that,
until the youngest Insured's attained insurance age 85 (or 15
policy years, if later), the Policy will not lapse even if the Cash
Surrender Value cannot cover the monthly deduction on a monthly
date if (a) equals or exceeds (b) where:

     (a)  is the sum of all premiums paid minus any partial
          surrenders and minus any indebtedness, and

     (b)  is the Death Benefit Guarantee to Age 85 premiums shown
          in the Policy that have been due since the Policy Date,
          including the current month.

     The Death Benefit Guarantee to Age 100 provision provides
that, until the youngest Insured's attained insurance age 100, the
Policy will not lapse even if the Cash Surrender Value cannot cover
the monthly deduction on a monthly date if (a) equals or exceeds
(b) where:

     (a)  is the sum of all premiums paid minus any partial
          surrenders and minus any indebtedness, and

     (b)  is the Death Benefit Guarantee to Age 100 premiums shown
          in the Policy that have been due since the Policy Date,
          including the current month.

     D. Loans

     The Policyowner may take loans under the Policy at any time as
long as the resulting indebtedness (including any existing
indebtedness) does not exceed 85% of the Policy Value, less
surrender charges.  The Policy is the only security for the loan. 
The requested loan amount will be taken from the Fixed Account and
the subaccounts in proportion to their respective values on the
date of the loan, unless the Policyowner requests a different
allocation.  Any loan taken from the subaccount will be transferred
to the Fixed Account.  The minimum loan amount is $500.  (For
further information about the loan provisions, see page 2.)

<PAGE>
PAGE 6
     The Policyowner may obtain a loan by sending a written request
or calling IDS Life.  IDS Life has the authority to honor any
telephone loan request believed to be authentic.  IDS Life is not
responsible for determining the authenticity of such calls.  A loan
request received before 3 p.m. Central time (which is 4 p.m. New
York time) will be processed the same day.  If the call or written
request is received after 3 p.m., the request will be processed the
following business day.

             CASH ADJUSTMENT UPON EXCHANGE OF CONTRACT

     At any time within 24 months of the Policy's Policy Date, the
Policyowner may exchange the Policy for a Flexible Premium
Survivorship Life Insurance Policy which provides for benefits that
do not vary with the investment return of the Variable Account. 
The exchange is accomplished by transferring all of the Policy
Value in the subaccounts to the Fixed Account.

                     POLICY SPLIT OPTION RIDER

     The Policy can be split on a 50/50 basis into two individual
permanent plans of life insurance then offered by IDS Life for
exchange, one on the life of each Insured, upon the occurrence of a
divorce of the Insureds or certain changes in federal estate tax
laws.  Evidence of insurability will not be required by IDS Life. 
The Specified Amount and Policy Value minus policy loans and
accrued loan interest will be divided evenly between the two
policies.



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