IDS LIFE VARIABLE LIFE SEPARATE ACCOUNT
N-8B-2, 1999-04-26
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SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C.  20549





AMENDMENT NO 7 TO FORM N-8B-2
FILE NO. 811-4298




DATED April 23, 1999





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>
                    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.

              Policy 1 - Single Premium Variable Life Insurance Policy

              Policy 2 - Flexible Premium Variable Universal Life Insurance 
                         Policy

              Policy 3 - Flexible Premium Survivorship Life Insurance Policy

              Policy 4 - Flexible Premium Variable Universal Life Insurance 
                         Policy (VUL-3)

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.

                  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.

<PAGE>
                          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 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.

<PAGE>
                  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 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.

<PAGE>
                  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
                  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,

                  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.

<PAGE>
                  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.

                  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.

<PAGE>
                  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.

                  Policy 4

                  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 10th day after you receive it (15th day in Colorado, 20th
                  day in Idaho and North Dakota).

                  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 10 policy years and in the 10 years following an
                  increase in specified amount a surrender charge will be
                  assessed. It reimburses IDS Life for costs of issuing the
                  policy, such as processing the application (primarily
                  underwriting) and setting up computer records. Partially
                  compensates IDS advisors' commissions, advertising and
                  printing the prospectus and sales literature.

                  The surrender charge for the initial specified amount will be
                  shown in the policy. It is based on the insured's insurance
                  age, sex, risk classification and initial specified amount.
                  The surrender charge for the initial specified amount will
                  remain level during the first five policy years and then
                  decrease monthly until it is zero at the end of 10 policy
                  years. If the specified amount is increased, an additional
                  surrender charge will apply. The additional surrender charge
                  will be shown in a revised policy. It will be based on the
                  insured's attained insurance age, sex, risk classification and
                  the amount of the ncrease. The additional surrender charge
                  will remain level during the first five years following the
                  effective date of the increase and then decrease monthly until
                  it is zero at the end of the 10th year following the increase.

                  If the owner surrenders part of the value of the 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 your policy.

                  The owner may surrender the policy in full or in part by
                  written or telephone request. IDS Life will process your
                  surrender request at the end of the valuation period during
                  which your request is received. IDS Life may require that the
                  owner return your policy.

                  IDS Life will normally process your payment within seven days;
                  however, it reserves the right to defer payment.

                  If the owner surrenders the policy totally, they receive its
                  cash surrender value -- the policy value minus outstanding
                  indebtedness and applicable surrender charges. We will compute
                  the value of each subaccount as of the end of the valuation
                  period during which your request is received.

<PAGE>
                  After the first policy year, the owner may surrender any
                  amount from $500 up to 90% 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,
                  described under "Loads, fees and charges."

                  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.

                  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 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.

<PAGE>
                  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.

                  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.

<PAGE>
                      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 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.

<PAGE>
                  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

                  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 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.

<PAGE>
                  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.

                  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.

                  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.

<PAGE>
                  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 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.

<PAGE>

                      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 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.

<PAGE>
                  Policy 4

                  Effect 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 no lapse
                             guarantee. The surrender amount is deducted from
                             total premiums paid, which may reduce the total
                             below the level required to keep the no lapse
                             guarantee in effect.

                      o      If Option 1 is in effect, the specified amount will
                             be reduced by the amount of the partial surrender
                             and fee. IDS Life will deduct this decrease from
                             the current specified amount in this order:

                             1. First from the specified amount provided by 
                                the most recent increase;
                             2. Next from the next most recent increases
                                successively; 
                             3. Then from the initial specified amount when 
                                the policy was issued.

                  Because they reduce the specified amount, partial surrenders
                  may affect the cost of insurance. IDS Life will not allow a
                  partial surrender if it 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, IDS Life will process the transfer request at the
                  end of the valuation period during which your request is
                  received. 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 with the necessary approval of the Securities and
                  Exchange Commission. 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
                           at any time for transfer periods the owner chooses
                           subject to certain minimums.

                      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 IDS Life receives it.

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

                      o    If the owner have 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.

                  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 are allowed.

                  Two ways to request a transfer, loan or surrender

                  The owner must provide their name, policy number, Social
                  Security Number or Taxpayer Identification Number when they
                  request a transfer.

                  1  By letter

                  Regular mail:

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

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

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

                      o    Telephone transfers are automatically available. The
                           owner may request that telephone transfers 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    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 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, they 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.

<PAGE>
                  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.

                  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.

<PAGE>
                  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.

                  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.

                  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.

<PAGE>
                  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 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.

<PAGE>
                  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.

                  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.

<PAGE>
                  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.

                  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.

                  Policy 4

                  Keeping the policy in force

                  No lapse guarantee

                  The NLG provides  that the policy will remain in force until
                  the insured's  attained age 70 (or 5 policy years, if later)
                  (always  five  policy  years if the policy is  purchased  in
                  Massachisetts  or Texas) even if the cash surrender value is
                  insufficient to pay the monthly deduction. The NLG will stay
                  in effect as long as:

                    o    the sum of premiums paid; minus
                    o    partial surrenders; minus
                    o    outstanding indebtedness; equals or exceeds
                    o    the minimum monthly premiums due since the policy date

                  The minimum monthly premium is shown in the policy.

                  If, on a monthly date, the owner has not paid enough premiums
                  to keep the no lapse guarantee in effect, the no lapse
                  guarantee will terminate. In addition, the policy will lapse
                  (terminate) if the cash surrender value is less than the
                  amount needed to pay the monthly deduction.

                  The no lapse guarantee period may be reinstated within 2 years
                  of its termination if the policy is in force.

<PAGE>

                  Grace period

                  If on a monthly date the cash surrender  value of the policy
                  is less  than the  amount  needed  to pay the  next  monthly
                  deduction  and the NLG is not in effect  the owner will have
                  61 days to pay the  required  premium  amount.  If the owner
                  does not pay the required premium, the policy will lapse.

                  IDS Life will mail a notice to their last known address,
                  requesting payment of a 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, it will use
                  the payment to cover all monthly deductions and any other
                  charges then due. IDS Life will add any balance 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 insured dies
                  during the grace period, any overdue monthly deductions will
                  be deducted from the death benefit.

                  Reinstatement

                  Your policy may be reinstated within five years after it
                  lapses, unless you surrendered it for cash. To reinstate, IDS
                  Life will require:

                      o      a written request;

                      o      evidence satisfactory to IDS Life that the insured 
                             remains insurable;

                      o      payment of the required reinstatement premium and

                      o      payment or reinstatement of any indebtedness.

                  The reinstatement premium is the required premium to reinstate
                  the policy.

                  The effective date of a reinstated policy will be the monthly
                  date on or next following the day IDS Life accepts your
                  application for reinstatement. The suicide period will apply
                  from the effective date of reinstatement (except in Georgia,
                  Nebraska, Oklahoma, Pennsylvania, South Carolina, Tennessee,
                  Utah and Virginia). Surrender charges will also be reinstated.

                  IDS Life will have two years from the effective date of
                  reinstatement to contest the truth of statements or
                  representations in the reinstatement application.

         (f)      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 Subaccount 2004 fund
                  the Single Premium Variable Life policies issued by IDS Life.
                  Subaccounts U, V, W, X, Y, IL, FEI, FGI, FNO, FPH, FSC, FVL
                  and FIF as well as Subaccount 2004V fund the Flexible Premium
                  Variable Life policies issued by IDS Life. Subaccounts U, V,
                  W, X, Y, IL, FGI and FNO 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

<PAGE>

                  in units of the Smith Barney Inc. Stripped (Zero Coupon) U.S.
                  Treasury Securities Fund, Series A ("the Trust"). 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; Subaccount
                  IL invests exclusively in the shares of the International
                  Equity Portfolio; Subaccount FEI invests exclusively in Equity
                  Income Portfolio. All of the above seven portfolios make up
                  IDS Life Series Fund, Inc., a series mutual fund. Subaccount
                  FGI invests exclusively in AIM V.I. Growth and Income Fund;
                  Subaccount FNO invests exclusively in Putnam VT New
                  Opportunities Fund - Class IA shares; Subaccount FPH invests
                  exclusively in Putnam VT High Yield Fund - Class IB shares;
                  Subaccount FSC invests exclusively in Warburg Pincus
                  Trust/Small Company Growth Portfolio; Subaccount FVL invests
                  exclusively in American Century VP Value; and Subaccount FIF
                  invests exclusively in Templeton International Fund - Class 2.
                  Subaccount 2004V invests in units of the designated
                  unit investment trust, with a maturity date of 2004. The IDS
                  Life Series Funds, AIM V.I. Growth and Income Fund, Putnam VT
                  New Opportunities Fund - Class IA, Putnam VT High Yield -
                  Class IB , Warburg Pincus Trust/Small Company Growth
                  Portfolio, American Century VP Value and Templeton
                  International Fund - Class 2 are herein referred to
                  collectively as ("the Funds").

                  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 seven 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 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.

<PAGE>

                  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 the Owners
                  of that action and its reasons for such action in the next
                  report to the 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 the
                  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.

                         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 the 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, the 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.

<PAGE>

         (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 the Owners is not required when changing the
                         underlying securities of any of the Subaccounts.
                         However, to change these securities, approval of the
                         Securities and 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 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.

<PAGE>

                  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 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.

<PAGE>

                  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 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.

<PAGE>
                  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.

                  Policy 4

                  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 first several policy years until the policy value
                  is sufficient to cover the surrender charge, IDS Life requires
                  that premiums sufficient to keep the no lapse guarantee in
                  effect be paid to keep the policy in force.

                  The owner may schedule payments annually, semiannually or
                  quarterly. (Payment at any other interval must be approved by
                  IDS Life.) IDS Life shows this premium schedule 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 the cash surrender value is sufficient
                  to pay the monthly deduction or if sufficient premiums have
                  been paid to keep the no lapse guarantee 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 payments will affect the policy
                  value, cash surrender value and length of time the policy will
                  remain in force, as well as affect whether the no lapse
                  guarantee remains in effect.

                  Premium limitations:
                  The owner may make unscheduled premium payments at any time
                  and in any amount of at least $25. 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 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 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.

<PAGE>

                  IDS Life  converts any amount that the owner  allocates to a
                  subaccount  into  accumulation  units  of  that  subaccount.
                  Similarly,   when  the   owner   transfers   value   between
                  subaccounts,  IDS Life  converts  accumulation  units in one
                  subaccount  into a cash value,  which IDS Life then converts
                  into accumulation units of the second subaccount.

                  Insurability:  Before issuing your policy, IDS Life requires
                  satisfactory  evidence  of the  insurability  of the  person
                  whose  life the  owner  proposes  to  insure  (the  owner or
                  someone  else) . IDS  Life's  underwriting  department  will
                  review the owner's  application and any medical  information
                  or other data  required to  determine  whether the  proposed
                  individual is insurable under IDS Life's underwriting rules.
                  The  owner's   application  may  be  declined  if  IDS  Life
                  determines  the  individual  is not  insurable  and IDS will
                  return any premiums the owner has paid.
                  
                  Age limit: IDS Life generally will not issue a policy where
                  the proposed insured is over the insurance age of 80. 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 insured dies.

                  If that death is prior to the 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 insured's death is on or after the 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 insured's 
                              death; or

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

                  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 your policy to qualify
                  as life insurance.

                  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 insureds death, if that death occurs 
                             on a valuation date, or on the next valuation date 
                             following the date of death.

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).

<PAGE>

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).

                  AIM Variable Insurance Funds, Inc.
                  Putnam Variable Trust
                  Warburg Pincus Trust
                  American Century Variable Portfolios, Inc.
                  Templeton Variable Products Series Fund

         (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

                  Investment manager of Putnam Variable Trust:
                  Putnam Investment Management, Inc.
                  One Post Office Square
                  Boston, MA 02109

                  Investment adviser of AIM Variable Insurance Funds, Inc.:
                  AIM Advisors, Inc.
                  11 Greenway Plaza
                  Suite 100
                  Houston, TX  77046-1173

                  Investment adviser of Warburg Pincus Trust
                  Warburg Pincus Asset Management
                  466 Lexington Avenue
                  New York, New York 10017-3147

                  Investment manager of American Century Variable Portfolios, 
                  Inc.
                  American Century Investment Management, Inc.
                  American Century Tower
                  4500 Main Street
                  Kansas City, MO 641111

                  Investment manager of Templeton Variable Products Series Fund
                  Templeton Investment Counsel, Inc.
                  100 Fountain Parkway
                  St. Petersburg, FL  33716

<PAGE>

         (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

                  For Putnam Variable Trust:
                  Putnam Fiduciary Trust Company, a wholly-owned subsidiary of 
                  Putnam Investments, Inc.

                  One Post Office Square
                  Boston, MA 02109

                  acts as custodian for Putnam VT New Opportunities - Class IA
                  and Putnam VT High Yield Fund - Class IB shares.

                  For A I M Variable Insurance Funds, Inc.:

                  State Street Bank & Trust Co.
                  225 Franklin Street
                  Boston, MA 02110

                  acts as custodian for A I M V.I. Growth and Income Fund.

                  For American Century Portfolios, Inc.:
                  P.O. Box 419385
                  Kansas City, MO  64141

                  acts as custodian for American Century VP Value

                  For Warburg Pincus Trust:

                  PNC Bank, National Association
                  1600 Market Street
                  Philadelphia, PA 19103

                  acts as custodian for Warburg Pincus Trust/Small Company 
                  Growth Portfolio.

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

                  Not Applicable.

<PAGE>

         (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. The Equity Income Portfolio commenced
                  operations on May 3, 1999. A I M V.I. Growth and Income
                  Fund commenced operation in May 1994. Putnam VT New
                  Opportunities Fund - Class IA commenced operations in May
                  1994. Putnam VT High Yield Fund - Class IB commenced
                  operations in February 1988. Warburg Pincus Trust/Small
                  Company Growth Portfolio commenced operations in June 1995.
                  American Century VP Value commenced operations in May 1996.
                  Templeton International Fund - Class C commenced operations in
                  May 1992.

                  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>
<S>           <C>                         <C>                                       <C>                  <C>
Policy 1

              Nature of Charge            Amount                                    Person to whom       Services
                                                                                    Paid/Relationship

              Monthly cost of insurance   Tabular charge per $1,000 at risk,        IDS Life             Insurance
              charges                     varying by age, sex and insurance                              Protection
                                          rating of the insured

              Policy Issue and            $150 at time of issue                     IDS Life             Issue and
              Administrative Expense                                                                     Administrative
                                                                                                         Expense

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

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

<PAGE>

Policy 2
              Nature of charge            Amount                                    Person to whom       Services
                                                                                    Paid/Relationship

              Sales Charge                2.5% of Gross Premiums                    IDS Life             Sales Expenses

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

              Policy Fee                  Currently $5 per policy month, never to   IDS Life             Administrative
                                          exceed $7.50 per policy month. Waived                          Expenses
                                          for policies purchased on or after May
                                          1, 1991 with an initial specified
                                          amount of $350,000 or more.

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

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

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

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

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

              Contingent Deferred Sales   27.5% of Gross Premiums up to amount      IDS Life             Sales Expense at
              Charge (Issue)              shown in policy (conservative estimate                         Issue
                                          of one Guideline Annual 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

<PAGE>

              Contingent Deferred Sales   6.5% of Premiums attributable to the      IDS Life             Sales Expenses at
              Charge (Increase)           Increase or, if less Tabular amount per                        Increase
                                          $100 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

              Partial Surrender Fee       $25 or, if less, 2% of Policy Value       IDS Life             Transaction Costs
                                          surrendered

Policy 3      Nature of Charge            Amount                                    Person to whom       Services
                                                                                    Paid/Relationship

              Sales Charge                7.25% of all premiums paid.               IDS Life             Sales Expenses

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

              Federal Tax Charge          1.25% of each premium payment             IDS Life             Federal taxes

              Policy Fee                  Currently $30 per policy month, never     IDS Life             Administrative
                                          to exceed $30 per policy month.                                Expenses

              Cost of Insurance           The monthly cost of insurance times the   IDS Life             Insurance
                                          total of the death benefit minus the                           Protection
                                          policy value plus any other flat extra
                                          insurance charges.

              Cost                        of Policy Riders Determined by nature
                                          and amount of IDS Life Optional
                                          Insurance riders attached to policy.

              Contingent Deferred Issue   $4 per $1000 of the initial specified     IDS Life             Issue and
              and Administrative          amount of the policy, if it is                                 Underwriting
              Expense Charge (Surrender   surrendered during the first policy                            Expenses at Issue
              Charge)                     years, and then decreasing monthly
                                          until it is zero at the end of 15
                                          policy years.

              Partial Surrender Fee       $25 (or $2% of the amount surrendered,    IDS Life             Transaction Costs
                                          if less).

<PAGE>

         (2) Underlying Security.

              Investment Management Fee   The Money Market Portfolio of IDS Life    IDS Life             Investment
                                          Series Fund, Inc. pays a fee on an                             management and
                                          annual basis equal to 0.50% of its                             services described
                                          daily aggregate average net assets.                            in Agreement

                                          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.

              Non-Advisory Expense        IDS Life Series Fund, Inc. will           IDS Life             Non-Advisory
              Charges                     reimburse IDS Life for non-advisory                            Expenses described
                                          expenses.                                                      in Agreement

Policy 4      Nature of Charge            Amount                                    Person to whom       Services
                                                                                    Paid/Relationship

              Premium Expense Charge      5.0% of premium payment.                  IDS Life             Distribution of
                                                                                                         policy; State and
                                                                                                         governmental taxes

              Policy Fee                  $5 per month for amount below $250,000,   IDS Life             Administrative
                                          and $0 per month or amounts above                              Expenses
                                          $250,000, never to exceed $7.50 per
                                          month.

              Cost of Insurance           The monthly cost of insurance times the   IDS Life             Insurance
                                          total of the death benefit minus the                           Protection
                                          policy value plus any other flat extra
                                          insurance charges.

              Cost                        of Policy Riders Determined by nature
                                          and amount of IDS Life Optional
                                          Insurance riders attached to policy.

              Partial Surrender Fee       $25 (or 2% of the amount surrendered,     IDS Life             Transactional Costs
                                          if less).

              Surrender Charge            Determined based on the insureds age,     IDS Life             Sales, issue and
                                          sex, risk classification and initial                           underwriting
                                          specified amount. Remains level for 5                          expense at issue
                                          years and then decreases monthly until
                                          it is zero at the end of 10 policy
                                          years.

<PAGE>

         (2)      Underlying Security.

              Investment Management Fee   The Money Market Portfolio of IDS Life    IDS Life             Investment
                                          Series Fund, Inc. pays a fee on an                             management and
                                          annual basis equal to 0.50% of its                             services described
                                          daily aggregate average net assets.                            in Agreement

                                          The Equity, Equity Income, 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.

                                          Putnam VT New Opportunities Fund Class
                                          IA shares pays a fee on an annual
                                          basis of 0.58% of its average daily
                                          net assets.

                                          Putnam VT High Yield Fund - Class IB
                                          shares pays a fee on an annual basis of
                                          0.66% of its average daily net assets.

                                          AIM V.I. Growth and Income Fund pays a
                                          fee on an annual basis of 0.63% of its
                                          average daily net assets.

                                          Warburg Pincus Trust/Small Company
                                          Growth Portfolio pays a fee on an
                                          annual basis of 0.90% of its average
                                          daily net assets.

                                          American Century VP Value pays a fee on
                                          an annual basis of 1.00% of its average
                                          daily net assets.

                                          Templeton International Fund - Class 2
                                          pays a fee on an annual basis 0.69% of
                                          its average daily net assets.

              Non-Advisory Expense        IDS Life Series Fund, Inc. will           IDS Life             Non-Advisory
              Charges                     reimburse IDS Life for non-advisory                            Expenses described
                                          expenses.                                                      in Agreement

</TABLE>

<PAGE>

         (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).

                  Policy 4

                  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>

                  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.

                  Policy 4

                           Not applicable

             (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.

                  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.

<PAGE>
                  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:

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

                      o      Expense 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.

                  Policy 4

                  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 average daily net asset value of the subaccounts for the
                  first  10  policy  years  and  0.45%  thereafter.  IDS  Life
                  reserves  the  right to  charge  up to 0.9%  for all  policy
                  years. Computed daily, the charge compensates IDS Life for:

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

                      o      Expense risk -- the risk that the policy fee and
                             the surrender charge may be insufficient to cover
                             the cost of administering the policy.

                  Any profit from the  mortality and expense risk charge 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
                  premium expense charge and surrender charges.  IDS Life will
                  make up any further deficit from its general assets.

<PAGE>

         (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 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.

                  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.

                  Policy 1, 2, and 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:

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

                      o      Expense 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.

                  Any profit from the mortality and expense risk charge 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.

<PAGE>

                  Policy 4

                  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 for the first 10
                  policy years and 0.45% thereafter. IDS Life reserves the right
                  to charge up to 0.9% for all policy years. Computed daily, the
                  charge compensates IDS Life for:

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

                      o      Expense risk -- the risk that the policy fee and
                             the surrender charge may be insufficient to cover 
                             the cost of administering the policy.

                  Any profit from the mortality and expense risk charge would be
                  available to IDS Life for any proper corporate purpose
                  including, among others, payment of sales and distribution
                  expenses, which IDS Life does not expect to be covered by the
                  premium expense charge and surrender 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>

         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 and 4

         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

         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

<PAGE>

         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 and 4

         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.

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, Policy 3 and
                  Policy 4. 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.

<PAGE>

                  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 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.

         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.

<PAGE>

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.

                  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.

<PAGE>

                  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 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>

                  Payment of loaned funds: Generally, IDS Life will pay loans
                  within seven days after IDS Life receives the owner's request.

                  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.

                  Policy 4

                  Policy loans

                  The Owner may borrow against the policy by written or
                  telephone request. IDS Life will process the loan request at
                  the end of the valuation period during which the request is
                  received. (Loans by telephone are limited to $50,000.)

                  Interest rate: The interest rate for policy loans is 6% per
                  year. After the 10th anniversary IDS Life expects to reduce
                  the loan interest 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 Alabama, 100% of the policy value minus surrender 
                           charges.

                      o    In all other states, 90% 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 it receives the loan
                  request.  The amount available at any time for a new loan is
                  the maximum loan value less any existing indebtedness.  When
                  IDS Life computes the amount available IDS Life reserves the
                  right to deduct from the loan value  interest for the period
                  until the next policy  anniversary  and  monthly  deductions
                  that IDS Life will take until the next policy anniversary.

                  Payment of loaned funds: Generally, IDS Life will pay loans
                  within seven days after it receives the request.

<PAGE>

                  Allocation  of  loans to  accounts:  If the  owner  does not
                  specify  whether the loan is to come from the fixed  account
                  or  the  subaccounts,   IDS  Life  will  take  it  from  the
                  subaccounts  and the fixed  account in  proportion  to their
                  values, minus indebtedness.  When IDS Life makes a loan from
                  a  subaccount,  IDS  Life  redeems  accumulation  units  and
                  tranfers the proceeds into the fixed account.  IDS Life will
                  credit the loaned amount with 4.0% annual interest.

                  Repayments: IDS Life will allocate to subaccounts
                  and/or the fixed account using the premium allocation
                  percentages in effect unless the owner tells us otherwise.
                  Repayments must be in amounts of at least $25.

                  Deferral of payments:
                  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 
                             (IDS Life has not collected good payment);

                      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.

                  IDS Life may delay the  payment  of any loans or  surrenders
                  from the fixed  account 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,  it 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 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.
<PAGE>
                  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.

                  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.

                  Policy 4

                  Allocation  of  loans to  accounts:  If the  owner  does not
                  specify  whether the loan is to come from the fixed  account
                  or  the  subaccounts,   IDS  Life  will  take  it  from  the
                  subaccounts  and the fixed  account in  proportion  to their
                  values, minus indebtedness.  When IDS Life makes a loan from
                  a subaccount,  IDS Life redeems  accumulation  units and the
                  proceeds  transferred into the fixed account.  IDS Life will
                  credit the loaned amount with 4.0% annual interest.

<PAGE>
                  Overdue interest: If the owner does not pay accrued interest
                  when it is  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 allocated interest IDS Life will take all of the interest 
                  from all of the accounts in proportion to their value, minus
                  indebtedness.

                  Effects of policy loans: If the owner does not repay the loan,
                  it will reduce the death benefit and cash surrender value.
                  Even if the owner does repay it, the 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)

         (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, 2, and 3 the outstanding loan balance for fiscal
                  year 1997 was $45,654,051 and the amount of interest collected
                  was $3,296,746.

                  No loans were in default for Policy 1, Policy 2, Policy 3 or
                  Policy 4.

                  For Policy 4 there was no outstanding loan balance.


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>

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>
                                                                                                             Aggregate
                      Total purchase     Amount of        Amount of        Amount of        Amount of        gross amount
                      payments by        sales load       administration   management       other fees       of load, fees,
Year                  security holders   received         fees received    fees received    received         etc. received.
Policy 1, 2 and 3
<S>                   <C>                <C>              <C>              <C>              <C>              <C>
1995                     $144,085,169       $10,125,762     $43,263,408    0                0                  $197,474,339
1996                      227,409,333        11,956,753      58,305,937    0                0                   297,672,023
1997                      303,291,329        14,502,145      78,172,136    0                0                   395,965,610
</TABLE>
Policy 4

Not applicable

         (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 1997, the aggregate amount of this management fee
                  was $7,667,720.

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.

         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.

<PAGE>

         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.
<TABLE>
<CAPTION>
                  Name and Address                        Principal Occupation
<S>                                               <C>
                  David R. Hubers                 Director since September 1989; president and chief executive 
                  IDS Tower 10                    officer, American Express Financial Corporation (AEFC), since 
                  Minneapolis, MN                 August 1993, and director, AEFC, since January 1984; senior vice
                                                  president, Finance and chief financial officer, AEFC, from                       
                                                  January 1984 to August 1993.

                  Richard W. Kling                Director since February 1984; president since March 1994, 
                  IDS Tower 10                    executive vice president, Marketing and Products from 
                  Minneapolis, MN                 January 1988 to March 1994, Vice president, AEFC, since
                                                  May 1994; director of IDS Life Series Fund, Inc. and
                                                  chairman of the board of managers of IDS Life Variable
                                                  Annuity Funds A and B.

                  Paul F. Kolkman                 Director since May 1984; executive vice president since 
                  IDS Tower 10                    March 1994; vice president, Finance from May 1984 to March 
                  Minneapolis, MN                 1994; vice president, AEFC, since January 1987.

                  James A. Mitchell               Chairman of the board since March 1994; director since July 
                  IDS Tower 10                    1984; chief executive officer since November 1986; president 
                  Minneapolis, MN                 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.

<PAGE>
                  Barry J. Murphy                 Director and executive vice president, Client Service, since 
                  IDS Tower 10                    March 1994; senior vice president, Operations, Travel Related 
                  Minneapolis, MN                 Services (TRS), a subsidiary of American Express Company, since 
                                                  July 1992; vice president, TRS, from November 1989 to July 1992;
                                                  chief operating officer, TRS, from March 1988 to November 1989.

                  Stuart A. Sedlacek              Director, vice president and chief financial officer of AEFC 
                  IDS Tower 10                    since January 1998; vice president - assured assets, AEFC from 
                  Minneapolis, MN                 1994 to 1997
</TABLE>
                  Principal Officers.

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

                  Jeffrey S. Horton
                  Vice president and treasurer since December 1997; vice
                  President and corporate treasurer, AEFC, since December 1997;
                  controller, American Express Technologies Financial Services,
                  AEFC, from July 1997 to December 1997; Controller, Risk
                  Management Products, AEFC, from June 1990 to May 1994.

                  William A. Stoltzmann
                  Vice President, general counsel and secretary since 1985; vice
                  president and assistant general counsel, AEFC, since November
                  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>

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:

                  The three highest received in total $4,864,941. James A.
                  Mitchell, Barry Murphy and Stuart Sedlacek.

         (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:

                  $5,073,153 in total excluding the amount in 31(a).

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

                  1998 - $9,938,094.

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:

                  $9,252,335

         (b)      indirectly or through subsidiaries to directors:

                  See Item 32(a).

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  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.

<PAGE>

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.

<PAGE>

                          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.

                  (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 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.

<PAGE>

         (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).

                  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.

                  Policy 4

                  IDS Life will pay a commission of up to 50 percent of the
                  initial Target Premium (annualized) when the policy is sold,
                  plus up to 3 percent of all premiums in excess of the target
                  premium. Each calendar quarter the policy is in force, IDS
                  Life will pay .0125 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 Manager of the
                  selling representative.

<PAGE>

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.

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.

<PAGE>

         (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.

         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 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>

                  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.

                  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.

<PAGE>

                  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 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. 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.

                  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.

         (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.

<PAGE>

                  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 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.

<PAGE>
                  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.

                  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.

<PAGE>

                  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:

                  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.

                  Policy 4

                  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:

                    o    the portion of the owner's initial net premium that the
                         owner has allocated to the fixed account; plus
                    o    interest accrued before the policy date; minus
                    o    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 account if the
                           date of calculation is a monthly date.
<PAGE>
                  Subaccount values

                  The value in each subaccount changes daily, depending on the
                  investment performance of the funds 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 of each subaccount
                  on the policy date equals:

                    o    the portion of your  initial net premium  allocated  to
                         the subaccount; plus
                    o    interest accrued before the policy date; minus
                    o    the  portion  of the  monthly  deduction  for the first
                         policy   month   that  you  have   allocated   to  that
                         subaccount.

                  The value on each subaccount on each valuation date equals:

                      o    the value of the subaccount on the preceding
                           valuation date, multiplied by the net investment fact
                           or 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:  IDS Life  converts  the  policy  value
                  allocated to each subaccount into  accumulation  units. Each
                  time the owner directs a premium  payment or transfer policy
                  value  into one of the  subaccounts,  a  certain  number  of
                  accumulation  units are  credited to the owner's  policy for
                  that  subaccount.  Conversely,  each time the owner  takes a
                  partial surrender or transfer value out of a subaccount, IDS
                  Life subtracts a certain number of accumulation units.

                  Accumulation units are the true measure of investment value in
                  each subaccount. For subaccounts investing in the funds,
                  they're related to, but not the same as, the net asset value
                  of the corresponding funds. The dollar value of each
                  accumulation unit can rise or fall daily, depending on the
                  investment performance of the underlying funds, 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 your investment (net
                  premium or transfer amount) by the current accumulation unit
                  value.

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

<PAGE>

                  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 fund; plus

                      o    per-share amount of any dividend or capital gain 
                           distribution made by the relevant fund 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 fund 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:

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

                      o changes in underlying funds net asset value; 
                      o dividends distributed to the subaccount(s); 
                      o capital gains or losses of underlying funds; 
                      o fund 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.

<PAGE>

         (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.

                         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.

<PAGE>

         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 purchase of underlying securities or interests
         therein from Owners who exercise surrender rights.

         Policy 2, Policy 3 and Policy 4

         The Subaccounts will maintain positions in the Fund(s) shares or Trust
         units by purchasing Fund(s) 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(s) 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 the Owners who exercise surrender rights.

<PAGE>

                          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 provisions of any indenture
         or agreement with respect thereto.

         Not applicable.

<PAGE>

                          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 and 4

                  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. Under Policy 4, the company assumes the risks under the
                  no lapse guarantee if the minimum monthly premiums are timely
                  paid.

         (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.

<PAGE>

         (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.

                  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.

<PAGE>

                  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.

                  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.

                  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.

<PAGE>

                  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.

                  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.

<PAGE>

                  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 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.

<PAGE>
                  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.

                  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.

                  Policy 4

                  Payment of premiums:
                  In applying for the policy, the owner decides how much he/she
                  intends to pay and how often the owner will make payments.
                  During the first several policy years until the policy value
                  is sufficient to cover the surrender charge, IDS Life requires
                  that premiums sufficient to keep the no lapse guarantee in
                  effect be paid to keep the policy in force.

                  The owner may  schedule  payments  annually,  semiannually  or
                  quarterly.  (Payment at any other interval must be approved by
                  IDS Life.) IDS Life shows this premium schedule 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 the cash surrender value is sufficient
                  to pay the monthly deduction or if the owner has paid
                  sufficient premiums to keep the no lapse guarantee 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 have flexibility in paying premiums,
                  the amount and frequency of the payments will affect the
                  policy value, cash surrender value and length of time the
                  policy will remain in force, as well as affect whether the no
                  lapse guarantee remains in effect.

                  Keeping the policy in force

                  No lapse guarantee

                  The NLG  provides  that the policy  will remain in force until
                  the insured's  attained age 70 (or 5 policy  years,  if later)
                  (always  five  policy  years if the  policy  is  purchased  in
                  Massachusetts  or Texas) even if the cash  surrender  value is
                  insufficient to pay the monthly  deduction.  The NLG will stay
                  in effect as long as:

                  o    the sum of premiums paid; minus 
                  o    partial surrenders; minus
                  o    outstanding indebtedness; equals or exceeds
                  o    the minimum  monthly  premiums due since the policy date

                  The minimum monthly premium is shown in the policy.

                  If, on a monthly date, the owner has not paid enough premiums
                  to keep the no lapse guarantee in effect, the no lapse
                  guarantee will terminate. In addition, the policy will lapse
                  (terminate) if the cash surrender value is less than the
                  amount needed to pay the monthly deduction.

                  The no lapse guarantee period may be reinstated within 2 years
                  of its termination if the policy is in force.
<PAGE>
                  Grace period

                  If on a monthly date the cash surrender value of the policy is
                  less than the amount needed to pay the next monthly  deduction
                  and the NLG is not in effect  the  owner  will have 61 days to
                  pay the  required  premium  amount.  If the owner does not apy
                  required premium, the policy will lapse.

                  IDS Life will mail a notice to the owner's last known address,
                  requesting payment of a 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 cover all monthly deductions and any
                  other charges then due. IDS Life will add any balance to the
                  policy value and allocate 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 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.

<PAGE>

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 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>

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.

<PAGE>

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:

         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.)

<PAGE>

         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 0.6% 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>
<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
</TABLE>
<PAGE>

(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>
<TABLE>
<CAPTION>
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%
- ------------------------------------------------------------------------------------------------------------------------
<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     3,380     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

</TABLE>
<PAGE>

(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
orsustained over any period of time.

<PAGE>
<TABLE>
<CAPTION>
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%
- ------------------------------------------------------------------------------------------------------------------------
<S>     <C>         <C>       <C>        <C>          <C>        <C>       <C>      <C>      <C>       <C>     
     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
</TABLE>

<PAGE>

(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.

         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.

         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.

<PAGE>

         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% 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.

<PAGE>
<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
</TABLE>
<PAGE>

(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>
<TABLE>
<CAPTION>
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%
- ----------------------------------------------------------------------------------------------------------------
<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    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
</TABLE>
<PAGE>

(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>
<TABLE>
<CAPTION>
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%
- ------------------------------------------------------------------------------------------------------------------------
<S>    <C>         <C>        <C>        <C>         <C>       <C>       <C>      <C>       <C>        <C>
   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
</TABLE>

<PAGE>

(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>
<TABLE>
<CAPTION>

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%
- ------------------------------------------------------------------------------------------------------------------------
<S>     <C>       <C>        <C>         <C>         <C>       <C>      <C>        <C>       <C>        <C>   
   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
</TABLE>

<PAGE>

(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.

Policy 4

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:

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

This type of illustration involves a number of detailed assumptions. To the
extent that the owner's own circumstances differ from those assumed in the
illustrations, the owner's expected results also would differ.

Upon request, IDS Life will furnish the owner with comparable tables
illustrating death benefits, policy values and cash surrender values based on
the actual age of the person the owner proposes to insure and on an initial
specified amount and premium payment schedule. In addition, after the owner has
purchased a policy, the owner may request illustrations based on policy values
at the time of request.

Understanding the illustrations:
Rates of return: assumes 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:  assumes a male  insurance age 35, in a standard  risk  classification,
qualifying  for the nonsmoker  rate.  Results would be lower if the insured
were  in a  substandard  risk  classification  or did not  qualify  for the
non-smoker rate.

Premiums: assumes a $900 premium is 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:  assumes that none have been made. (Since
IDS Life assumes  indebtedness  is zero, the cash  surrender  value in all cases
equals the policy value minus the surrender charge.)

<PAGE>

Effect of expenses and charges: 

The death benefit,  policy value and cash surrender  value reflect the following
charges:

o    Premium expense charge: 5% of each premium payment.
o    Cost of insurance charge for the sex, age and rate  classification  for the
     assumed insured.
o    Policy fee: $5 per month ($7.50 per month guaranteed maximum).
o    The expenses  paid by the fund and charges made against the  subaccount  as
     described below:

The net investment  return of the subaccounts  shown in the tables is lower than
the gross,  after-tax  return of the fund because IDS Life deducted the 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  average  daily  net
     assets; the assumed investment  management fee is approximately  equal to a
     simple average of the  investment  management  fees of the funds  available
     under the  policy.  The actual  charges  you incur  will  depend on how you
     choose to allocate policy value.

o    the daily  mortality  and expense  risk charge,  equivalent  to 0.9% of the
     average daily net asset value of the subaccounts  annually for the first 10
     policy years and 0.45% thereafter, IDS Life reserves the right to charge up
     to 0.9% for all policy years.

o    a nonadvisory  expense  charge,  assumed to be 0.1% of each fund's  average
     daily net assets for direct expenses incurred by the fund; currently,  this
     is the maximum  direct  expenses the funds will incur after IDS Life limits
     the direct expenses of some funds. The actual charges the owner incurs will
     depend on how the owner chooses to allocate the policy.

After deduction of the expenses and charges described above, the illustrated
gross annual investment rates of return correspond to the following approximate
net annual rates of return:
<TABLE>
<CAPTION>
                             Net annual rate of         Net annual rate of         Net annual rate of
                             return for "Guaranteed     return for "Current        return for "Current
Gross annual investment      costs assumed"             costs assumed"             costs assumed"
rate                         illustration               illustration, years        illustration, years
of return                                               1-10                       11 and after
<S>                         <C>                        <C>                       <C>
 0%                          -1.69%                     -1.69%                     -1.24%

 6                             4.21                       4.21                       4.68

12                           10.11                      10.11                      10.61
</TABLE>
Taxes: Results shown in the tables reflect the fact that IDS Life does not
currently charge the subaccounts for federal income tax. If we take such a
charge 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>
<TABLE>
<CAPTION>

Illustration
- ---------------------------------------------------------------------------------------------------------
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        614        657        700         0         0        0
2          1,937      $100,000   $100,000   $100,000      1,209      1,333      1,463       308       432      562
3          2,979      $100,000   $100,000   $100,000      1,784      2,027      2,292       883     1,126    1,391
4          4,073      $100,000   $100,000   $100,000      2,335      2,737      3,191     1,434     1,836    2,290
5          5,222      $100,000   $100,000   $100,000      2,868      3,467      4,172     1,967     2,566    3,271

6          6,428      $100,000   $100,000   $100,000      3,375      4,212      5,236     2,654     3,491    4,515
7          7,694      $100,000   $100,000   $100,000      3,857      4,972      6,392     3,317     4,431    5,851
8          9,024      $100,000   $100,000   $100,000      4,316      5,749      7,651     3,956     5,389    7,291
9         10,420      $100,000   $100,000   $100,000      4,749      6,541      9,021     4,568     6,361    8,841
10        11,886      $100,000   $100,000   $100,000      5,153      7,346     10,512     5,153     7,346   10,512

11        13,425      $100,000   $100,000   $100,000      5,552      8,200     12,189     5,552     8,200   12,189
12        15,042      $100,000   $100,000   $100,000      5,922      9,072     14,025     5,922     9,072   14,025
13        16,739      $100,000   $100,000   $100,000      6,264      9,963     16,040     6,264     9,963   16,040
14        18,521      $100,000   $100,000   $100,000      6,576     10,873     18,252     6,576    10,873   18,252
15        20,392      $100,000   $100,000   $100,000      6,854     11,799     20,681     6,854    11,799   20,681

16        22,356      $100,000   $100,000   $100,000      7,095     12,739     23,348     7,095    12,739   23,348
17        24,419      $100,000   $100,000   $100,000      7,295     13,690     26,279     7,295    13,690   26,279
18        26,585      $100,000   $100,000   $100,000      7,447     14,646     29,501     7,447    14,646   29,501
19        28,859      $100,000   $100,000   $100,000      7,552     15,609     33,048     7,552    15,609   33,048
20        31,247      $100,000   $100,000   $100,000      7,598     16,570     36,955     7,598    16,570   36,955

age 60    45,102      $100,000   $100,000   $100,000      6,784     21,209     63,603     6,784    21,209   63,603
age 65    62,785      $100,000   $100,000   $132,317      3,559     25,064    108,456     3,559    25,064  108,456

</TABLE>
<PAGE>

(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 the owner
should not consider  them to be 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. IDS Life
cannot represent that these hypothetical rates of return can be achieved for any
one year or sustained over any period of time.

<PAGE>
<TABLE>
<CAPTION>
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%
- --------------------------------------------------------------------------------------------------------------------
<S>    <C>        <C>        <C>        <C>           <C>        <C>       <C>        <C>       <C>      <C>
1       $  945     $100,000   $100,000   $100,000        584        626       668          0         0        0
2        1,937     $100,000   $100,000   $100,000      1,150      1,270     1,396        249       369      495
3        2,979     $100,000   $100,000   $100,000      1,696      1,931     2,187        795     1,030    1,286
4        4,073     $100,000   $100,000   $100,000      2,219      2,606     3,044      1,318     1,705    2,143
5        5,222     $100,000   $100,000   $100,000      2,723      3,299     3,977      1,822     2,398    3,076

6        6,428     $100,000   $100,000   $100,000      3,203      4,006     4,989      2,482     3,285    4,268
7        7,694     $100,000   $100,000   $100,000      3,658      4,726     6,088      3,117     4,185    5,548
8        9,024     $100,000   $100,000   $100,000      4,090      5,461     7,284      3,729     5,101    6,924
9       10,420     $100,000   $100,000   $100,000      4,496      6,209     8,584      4,315     6,029    8,404
10      11,886     $100,000   $100,000   $100,000      4,873      6,969     9,998      4,873     6,969    9,998

11      13,425     $100,000   $100,000   $100,000      5,221      7,737    11,533      5,221     7,737   11,533
12      15,042     $100,000   $100,000   $100,000      5,538      8,515    13,205      5,538     8,515   13,205
13      16,739     $100,000   $100,000   $100,000      5,823      9,302    15,026      5,823     9,302   15,026
14      18,521     $100,000   $100,000   $100,000      6,075     10,094    17,011      6,075    10,094   17,011
15      20,392     $100,000   $100,000   $100,000      6,289     10,891    19,174      6,289    10,891   19,174

16      22,356     $100,000   $100,000   $100,000      6,463     11,688    21,533      6,463    11,688   21,533
17      24,419     $100,000   $100,000   $100,000      6,590     12,479    24,104      6,590    12,479   24,104
18      26,585     $100,000   $100,000   $100,000      6,666     13,260    26,910      6,666    13,260   26,910
19      28,859     $100,000   $100,000   $100,000      6,683     14,024    29,971      6,683    14,024   29,971
20      31,247     $100,000   $100,000   $100,000      6,637     14,766    33,315      6,637    14,766   33,315

age 60  45,102     $100,000   $100,000   $100,000      5,216     17,893    55,543      5,216    17,893   55,543
age 65  62,785     $100,000   $100,000   $112,343        764     18,976    92,085        764    18,976   92,085
</TABLE>
<PAGE>

(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 the owner
should not consider  them to be 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. IDS Life
cannot represent that these hypothetical rates of return can be achieved for any
one year or sustained over any period of time.

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.

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

     Filed electronically as Part I to the Pre-Effective Amendment No. 1 on Form
     S-6 (Form No. 333-69777) to the original Registration  Statement and herein
     is incorporated by reference.

     Financial Statements of the Depositor

     Filed electronically as Part I to the Pre-Effective Amendment No. 1 on Form
     S-6 (Form No. 333-69777) to the original Registration  Statement and herein
     is incorporated by reference.

<PAGE>

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**
             (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 as Exhibit 1.A.3(c) to 
             Pre-Effective Amendment No. 1 to the Registration Statement on
             Form S-6, File No. 333-69777 and is herein incorporated by
             reference.
     (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*** 
         (d) Flexible Premium Variable Life Insurance Policy (VUL-3) filed as 
             Exhibit 1.A.5(b) to Pre-Effective Amendment No. 1 to the 
             Registration Statement on Form S-6, File No. 333-69777 and is 
             herein incorporated by reference.
     (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*****
         (d) Addendum to Investment Advisory Agreement*****
     (9) None. 
     (10)(a)  Application form for the Single Premium VariableLife 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*****
         (d)  Application form for the Flexible Premium Variable Life Insurance
              Policy (VUL-3) filed as Exhibit 1.A.10 to Pre-Effective 
              Amendment No. 1 to the Registration Statement on Form S-6, File 
              No. 333-69777 and is herein incorporated by reference.
     (11) Memorandum on Transfer and Redemption Procedures, and Method of
          Computing Adjustments on Conversions filed as Exhibit 1.A.11 to 
          Pre-Effective Amendment No. 1 to the Registration Statement on
          Form S-6, File No. 333-69777 and is herein incorporated by reference.
     (12)(a) Power of attorney dated August 19, 1997**** 
         (b) Power of Attorney dated April 9, 1998****
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.
***Filed as an Exhibit to Amendment No. 5 of the original Registration to Form 
N-8B-2 File No. 811-4298
****Filed as an Exhibit to Post-Effective Amendment No. 3 to the Registration 
Statement on Form S-6 File No. 33-62457 and herein incorporated by reference.
*****Filed as an Exhibit to Amendment No. 6 of the original Registration to Form
N-8B-2 File No. 811-4298.

<PAGE>

Pursuant  to the  requirements  of the  Investment  Company  Act  of  1940,  the
depositor of the Registrant  has cause this Amendment No. 7 to the  Registration
Statement  to be  duly  signed  on  behalf  of the  Registrant  in  Minneapolis,
Minnesota on April 23, 1999.

IDS Life VARIABLE LIFE SEPARATE ACCOUNT

BY IDS Life INSURANCE COMPANY
(Depositor)


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



By /s/ Mary Ellyn Minenko
         Mary Ellyn Minenko


Attest: /s/ William A. Stoltzmann
         William A. Stoltzmann

              Vice President, General Counsel and Secretary
         IDS Life Insurance Company

*Signed pursuant to Power of Attorney dated April 14, 1999 filed  electronically
as an exhibit to  Pre-Effective  Amendment  No. 1 of the  original  Registration
Statement  to Form  S-6,  File  No.  333-69777  and is  herein  incorporated  by
reference.




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