IDS LIFE OF NEW YORK ACCOUNT 8, N-8B-2/A, 1998-04-09

IDS LIFE OF NEW YORK ACCOUNT 8
N-8B-2/A, 1998-04-09

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SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, DC 20549

Amendment No. 5

FORM N-8B-2

REGISTRATION STATEMENT OF UNIT INVESTMENT TRUSTS
WHICH ARE CURRENTLY ISSUING SECURITIES

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

IDS Life of New York Account 8

Issuer of Periodic Payment Plan Certificates

C/O IDS Life Insurance Company of New York
20 Madison Avenue Ext.
Albany, NY 12203

<PAGE>
I.

ORGANIZATION AND GENERAL INFORMATION

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

IDS Life of New York Account 8 (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.

Flexible Premium Variable Life Insurance Policy. ("Policy 1")

Flexible Premium Variable Survivorship Life Insurance Policy ("Policy
2")

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 of New York ("IDS Life of New York") 20 Madison
Avenue Extension, Albany, NY 12203 IRS Employer #41-0987741

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.

American Express Financial Advisors, Inc., IDS Tower 10, Minneapolis, MN
55440, IRS Employer #41-0973005.

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

New York

6. (a) Furnish the dates of execution and termination of any indenture or
agreement currently in effect under the terms of which the trust was
organized and issued or proposes to issue securities.

The Variable Account was established as a separate account of IDS Life
of New York pursuant to a resolution of the Board of Directors of IDS
Life of New York adopted on September 12, 1985.
<PAGE>
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 of New York 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.

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.

There are no material legal proceedings to which the Variable Account is
subject. IDS Life of New York is engaged in various kinds of routine
litigation that, in IDS Life of New York's judgment, are not of material
importance in relation to its assets. None of such litigation relates to
the Variable Account.

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.
<PAGE>

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 of New York, and ownership cannot be transferred except
upon notice to IDS Life of New York.

(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.

Policy 1

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 of New York 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 by
the 10th day after IDS Life of New York 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 of New York at its home office. The Owner also may
request a partial surrender by calling IDS Life of New York. IDS Life
of New York has the authority to honor any telephone surrender request
believed to be authentic. IDS Life of New York is not responsible for
determining the authenticity of such calls. A surrender request
received before 4 p.m. Eastern time will be processed the same day. If
the call or written request is received after 4 p.m., the request will
be processed the following business day. IDS Life of New York may
require that the Policy be returned to it. IDS Life of New York 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 of New York at its
home office, however IDS Life of New York 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 not 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

<PAGE>

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 premiums 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 of New
York postpones payment more than 30 days, interest at an annual rate
of 4 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 of New
York 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 and The
Contingent Deferred Sales Charge.

The maximum Contingent Deferred Sales Charge and the maximum
Contingent Deferred Issue and Administrative Expense Charge for the
Initial Specified Amount or any requested increase in Specified Amount
will be determined on the Policy Date or on the effective date of any
such requested increase, as the case may be. In general, these maximum
charges remain level for the 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.

Policy 2

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 of New York or their financial advisor,
with a written request for cancellation, by the latest of:

o the 10th day after they have received it;

o the 10th day after IDS Life of New York mails or personally
delivers a written notice; 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 of New York for costs of
issuing the policy, such as processing the application (primarily
underwriting) and setting up computer records. 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.
<PAGE>

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 of New York may require the owner to return the policy.

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

IDS Life of New York 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 of New
York 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 4% for the period of postponement.

Total surrenders: If the owner surrenders the policy totally, they
will receive its cash surrender value - the policy value minus
outstanding indebtedness and applicable surrender charges. IDS Life of
New York will compute the value of each subaccount as of the end of
the valuation period during which the owner's request is received.

(d) The rights of security holders with respect to conversion, transfer,
partial redemption and similar matters.

Policy 1

By written request, or other requests acceptable to IDS Life of New
York, 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 of New York receives a valid complete transfer request. IDS
Life of New York may suspend or modify this transfer privilege at any
time with any necessary approval of the Securities and Exchange
Commission.

<PAGE>

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 of New York 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 of New
York 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 of
New York 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 of New York
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 of New York at any time.

The Owner also may request a transfer by calling IDS Life of New York.
IDS Life of New York has the authority to honor any telephone transfer
request believed to be authentic. IDS Life of New York is not
responsible for determining the authenticity of such calls.

A transfer request received before 4 p.m. Eastern time will be
processed the same day. If a call or written request is received after
4 p.m. Eastern time, the request will be processed the following
business day.

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 $25,000.

Unless the Owner specifies a different allocation, IDS Life of New
York 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
of New York will reduce the current Specified Amount by the amount of
the partial surrender in the following order:

<PAGE>

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

(b) the next most recent increases successively; and

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 of New York does not allow a partial surrender if the
Specified Amount after a partial surrender would be less than the
Minimum Specified Amount.

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

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

During the first two years after the Policy has been issued, the Owner
has the right on one occasion to exchange the Policy for a Flexible
Premium Adjustable 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 of New York will automatically credit
all future premium payments on the Policy to the Fixed Account unless
the Owner requests a different allocation.

Policy 2

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).

<PAGE>
Allocation of partial surrenders: Unless the owner specifies
otherwise, IDS Life of New York will make partial surrenders from the
fixed account and subaccounts in proportion to their values at the end
of the valuation period during which the request is received. In
determining these proportions, IDS Life of New York first subtracts
the amount of any outstanding indebtedness from the fixed account
value.

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 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-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 of New York 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 of New York receives the request before the close of business, it
will process it that day. Requests received after the close of
business will be processed the next business day. There is no charge
for transfers. Before transferring policy value, the owner should
consider the risks involved in switching investments.

IDS Life of New York may suspend or modify the transfer privilege at
any time with the necessary approval of the SEC and the New York
Superintendent of Insurance. 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.

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

o If the owner has made a transfer from the fixed account to one or
more subaccounts, they may not make a transfer from any
subaccount back to the fixed account until the next policy
anniversary. IDS Life of New York 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 of New York reserves the right to limit mail and telephone
transfers to twelve 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 when they request a transfer,
loan or partial surrender.

<PAGE>
1 By Letter

Regular Mail:

IDS Life of New York
P. O. Box 5144
Albany, NY 12205

Express mail

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

2 By phone

Call between 8 a.m. and 6 p.m. Eastern Time:
1-800-541-2251 (toll free) or (518) 869-8613 (Albany area)

o IDS Life of New York 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 of New York will honor any telephone transfer, loan or
partial surrender requests believed to be authentic and will use
reasonable procedures to confirm that they are. They include
asking identifying questions and tape recording calls. As long as
the procedures are followed, neither IDS Life of New York 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 of New York.

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. 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. Because this strategy involves continuous investing, the
owner's success will depend upon their willingness to continue to
invest regularly through periods of low price levels. Dollar-cost
averaging 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 of New York
will automatically credit all future premium payments to the fixed
account unless the owner requests a different allocation.

<PAGE>

Such transfer will not count against the twelve-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

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 of New York 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 of New York 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 being continued under
the Death Benefit Guarantee provision described below, all coverage
under the policy will terminate without value at the end of the 61-day
grace period.

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

Until the insured's attained age 65, or five years from the policy
date, whichever is later, the policy will not terminate even if the
cash surrender value is insufficient to cover the monthly deduction on
a monthly date if (a) equals or exceeds (b) where:

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

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

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

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

<PAGE>

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 65,
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
of New York 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
of New York;

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 of New York approves the
application for reinstatement.

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

Policy 2

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.

<PAGE>

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 initial premium until the policy value is
greater than the surrender charge and the cash surrender value is
sufficient to pay the monthly deduction.

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 minus partial surrenders minus
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-100 will be in effect. If the DBG-100 is 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 each
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.

<PAGE>

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 the DBG-100 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 of New York 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 of New York receives this
premium before the end of the 61-day grace period, IDS Life of New
York 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.

Reinstatement

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

o a written request;

o evidence satisfactory to IDS Life of New York 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;

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 of New York accepts the owner's
application for reinstatement. The suicide period will apply from the
effective date of reinstatement.
<PAGE>

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

(f) The substance of any provisions of any indenture or agreement with
respect to voting rights, together with the names of any persons other
than security holders given the right to exercise voting rights
pertaining to the trust's securities or the underlying securities and
the relationship of such persons to the trust.

Policy 1

The Variable Account is comprised of various subaccounts. The Equity,
Income, Money Market, Managed, Government Securities, International
Equity, YGI and YNO Subaccounts, as well as the 1991, 1995 and 2004
U.S. Treasury Securities Subaccounts fund the policy. Some Subaccounts
invest exclusively in the Portfolios of IDS Life Series Fund, Inc.
("the Fund"), while others invest in units of the Smith Barney
Stripped ("Zero Coupon") U.S. Treasury Securities Fund, Series A ("the
Trust" or "the Trusts"). The Equity Subaccount invests exclusively in
the shares of the Equity Portfolio; the Income Subaccount invests
exclusively in the shares of the Income Portfolio; the Money Market
Subaccount invests exclusively in the shares of Money Market
Portfolio; the Managed Subaccount invests exclusively in the shares of
the Managed Portfolio; the Government Securities Subaccount invests
exclusively in the shares of the Government Securities Portfolio; and
the International Equity Subaccount invests in shares of the
International Equity Portfolio. These six portfolios make up the IDS
Life Series Fund, Inc., a series mutual fund. The YGI Subaccount
invests exclusively in shares of the Growth and Income Fund. This fund
is part of the AIM Variable Insurance Funds, Inc., a series mutual
fund. The YNO Subaccount invests in shares of Putnam VT New
Opportunities Fund. This fund is a portfolio of Putnam Variable Trust,
a series mutual fund. The 1991, 1995 and 2004 U.S. Treasury Securities
Subaccounts invest in units of the designated unit investment trust,
with maturity dates of 1991, 1995 and 2004 respectively.

All shares issued by the Fund are the same class (kind) capital stock.
They have a par value of $.001 a share. They are fully paid and
nonassessable and can be redeemed or transferred. All shares have
equal voting rights. They can be issued as full shares or fractions. A
fraction of a share has the same kind of rights and privileges as a
full share. The Fund currently has five 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.

<PAGE>

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 of New York is the Owner
of those Fund shares and 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 of New York 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 of New York 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 of New York, but not more than 90 days before the meeting of the
Fund. Fractional votes are counted. Owners will receive notice of each
meeting of shareholders together with any proxy solicitation
materials, and a statement of the number of votes as to which they are
entitled to give directions at the meeting.

IDS Life of New York 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 of New York
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 of New York reasonably
disapproves such changes in accordance with applicable federal
regulations. If IDS Life of New York does disregard voting
instructions, it will advise Owners of that action and its reasons for
such action in the next report to Owners.

Generally, ownership of units of a unit investment trust does not
involve the exercise of voting rights. However, with regard to the
Trusts, unit holders 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 of New York, as the Owner of such units, would
solicit voting instructions from Owners under the same procedures set
forth above regarding the holders of Fund shares.

<PAGE>

Policy 2

The Variable Account is comprised of various subaccounts. The Equity,
Income, Money Market, Managed, Government Securities, International
Equity, YGI and YNO Subaccounts. Some Subaccounts invest exclusively
in the Portfolios of IDS Life Series Fund, Inc ("the Fund"), while
others in the AIM V.I. Growth and Income Fund ("the Growth and Income
Fund") and Putnam VT New Opportunities Fund ("the Putnam Fund"),
collectively referred to as ("the Funds"). The Equity Subaccount
invests exclusively in the shares of the Equity Portfolio; the Income
Subaccount invests exclusively in the shares of the Income Portfolio;
the Money Market Subaccount invests exclusively in the shares of Money
Market Portfolio; the Managed Subaccount invests exclusively in the
shares of the Managed Portfolio; the Government Securities Subaccount
invests exclusively in the shares of Government Securities Portfolio;
and the International Equity Subaccount invests in shares of the
International Equity Portfolio. These six portfolios make up the IDS
Life Series Fund, Inc., a series mutual fund. The YGI Subaccount
invests exclusively in shares of the Growth and Income Fund. This fund
is part of the AIM Variable Insurance Funds, Inc., a series mutual
fund. The YNO Subaccount invests exclusively in shares of the Putnam
VT New Opportunities Fund. This fund is a portfolio of Putnam Variable
Trust, a series mutual fund.

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 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.

<PAGE>

any other matter that may be voted upon at a shareholders' meeting.
However, IDS Life of New York 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 of New
York 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 of New York, but not more than 90 days before the meeting of the
Fund. Fractional votes are counted. Owners will receive notice of each
meeting of 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.

(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 of New York'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 of New York 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 of New York 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 or the insurance
department of the state of New York. IDS Life of New York will
notify Owners within five days of any substitution or change.

<PAGE>

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

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

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

Not applicable.

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

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

(h) Whether the consent of security holders is required in order for
action to be taken concerning any change in:

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

Consent of Owners is not required when changing the underlying
securities of any of the Subaccounts. However, to change these
securities, approval of the Securities and Exchange Commission
and the insurance department of the state of New York may be
necessary.

(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(b)(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 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

<PAGE>

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 of New York will accept is $25. IDS
Life of New York reserves the right to limit any payment. Currently
the maximum payment that IDS Life of New York will accept is $500,000.

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 of the Minimum Monthly Premium will
keep the coverage in force until the later of the insured's Age 65
Anniversary or five years from the policy date.

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

Before issuing any policy, IDS Life of New York requires evidence of
insurability satisfactory to it. IDS Life of New York 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.

Policy 2

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 of New York requires that the owner pay the minimum
initial premiums. The owner may schedule payments annually,
semiannually, or quarterly. (Payment at any other interval must be
approved by IDS Life of New York.) 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-100 or the minimum
initial premium period in effect.

<PAGE>

The owner may also change the amount and frequency of scheduled
premium payments by written request. IDS Life of New York 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-100 or the minimum initial premium
period remain in effect.

Premium limitations:

The owner may make unscheduled premium payments at any time and in the
amount of at least $50. IDS Life of New York 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 of New York 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 of New York holds all premiums in the
fixed account, and IDS Life of New York 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 of New York will
allocate the net premiums plus accrued interest to the account(s) the
owner has selected in their application. At that time, IDS Life of New
York will begin to assess the various loads, fees and charges.

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 of New York requires
satisfactory evidence of the insurability of the persons whose lives
the owner proposes to insure. IDS Life of New York'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 of New York'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.

<PAGE>
Age limit: The policy is available only to persons age 35 and older.
In addition, IDS Life of New York 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 of New York 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.

On the youngest insured's attained insurance age 100, the amount
payable is the cash surrender value.

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

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

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

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

o the policy value plus the specified amount; or

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

Information Concerning the Securities Underlying the Trust's Securities

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

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

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

(a) Name of Company.

(1) IDS Life Series Fund, Inc.

<PAGE>

(2) Smith Barney Inc. Stripped ("Zero Coupon") U.S. Treasury
Securities Fund, Series A.

(3) AIM Variable Insurance Funds, Inc.

(4) Putnam Variable Trust

(b) Name and principal address of depositor.

Investment manager of IDS Life Series Fund, Inc. is IDS Life Insurance
Company
Investment advisor of IDS Life Series Fund, Inc. is American Express
Financial Corporation
IDS Tower 10
Minneapolis, MN 55440

The sponsor of Smith Barney, Inc. Stripped ("Zero Coupon") U.S.
Treasury Securities Fund, Series A, is
Smith Barney, Inc.
Unit Trust Department
388 Greenwich St.
New York, NY 10013

Investment advisor of AIM V. I. Growth and Income Fund
A I M Advisors, Inc.
11 Greenway Plaza
Suite 100
Houston, TX 77046

Investment manager of Putnam VT New Opportunities Fund
Putnam Investment Management, Inc.
One Post Office Square
Boston, MA 02109

American Express Trust Company
1200 Northstar Center West
Minneapolis, MN 55402

acts as custodian for IDS Life Series Fund, Inc.

The Bank of New York
101 Barclay Street
New York, NY 10286

acts as custodian for the Smith Barney Inc. Stripped ("Zero Coupon")
U.S. Treasury Securities Fund, Series A.

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

<PAGE>

acts as custodian for the AIM V. I. Growth and Income Fund.

Putnam Fiduciary
Trust Company
One Post Office Square
Boston, MA 02109

acts as custodian for Putnam VT New Opportunities Fund.

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

IDS Life of New York
20 Madison Avenue Ext.
Albany, NY 12203

(e) The period during which the securities of such Company have been the
underlying securities.

IDS Life Series Fund - Equity, Money Market, Managed and Government
Securities subaccounts commenced operations on August 31, 1987. IDS
Life Series Fund International Equity subaccount commenced operations
on October 28, 1994. YGI subaccount (investing in AIM V. I. Growth and
Income Fund) and YNO subaccount (investing in Putnam VT New
Opportunities Fund) each commenced operations on November 22, 1996.
The 2004 subaccount (investing in Smith Barney, Inc. Stripped ("Zero
Coupon") U.S. Treasury Securities Fund, Series A) commenced operation
on August 31, 1987.

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.

Policy 1

(1) Principal Payments.
<TABLE>
<CAPTION>

<S> <C> <C> <C>
Nature of Charge Amount Person to whom Paid/Relationship Services

Sales Charge 2.5% of Gross Premiums IDS Life of New York Sales Expenses

Premium Tax Charge 1.0% of Gross Premiums IDS Life of New York State Premium Taxes

<PAGE>

Policy Fee $5 per policy per month IDS Life of New York Administrative
Expenses

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

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

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

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

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

Contingent 27.5% of Gross Premiums up to amount IDS Life of New York Sales Expenses at
Deferred Sales shown in policy (conservative estimate Issue (Issue)
Charge (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

Contingent 6.5% of Premiums attributable to the IDS Life of New York Sales Expenses at
Deferred Sales Increase or, if less, Tabular amount Increase
Charge (Increase) per $1000 increase 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 $25 or, if less, 2% of Policy Value IDS Life of New York Transaction Costs
Fee surrendered

<PAGE>

(2) Underlying Security

Investment The Money Market Portfolio of IDS Life IDS Life Investment
Management Fee Series Fund, Inc., pays a fee equal on management and
an annual basis to .50% of its daily services
net assets.

The Putnam VT New Opportunities Fund Putnam Investment
pays a fee of 0.63% of its daily net management and
assets. services

The A I M V. I. Growth and Income Fund A I M Investment
pays a fee of 0.65% of its daily net management and
assets. services

The Equity, Income, Managed and IDS Life
Government Securities Portfolios of
IDS Life Series Fund, Inc. each pay a
fee equal on an annual basis to .70%
of their daily net assets.

The International Equity Portfolio of IDS Life
IDS Life Series Fund, Inc. pays a fee
on an annual basis equal to 0.95% of
its average daily net assets.

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

Policy 2

(1) Principal Payments.

Nature of Charge Amount Person to whom Paid/Relationship Services

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

Premium Tax Charge 1.0% of premium payment. IDS Life of New York State Premium Taxes

Federal Tax Charge 1.25% of each premium payment. IDS Life of New York Federal Taxes

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

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

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

<PAGE>

Contingent $4 per $1,000 of the initial specified IDS Life of New York Issue and
Deferred Issue amount of the policy, if it is Underwriting
and surrendered during the first policy Expenses at Issue
Administrative years, and then decreasing monthly
Expense Charge until it is zero at the end of 15
(Surrender Charge) policy years.

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

(2) Underlying Security

Investment The Money Market Portfolio of IDS Life IDS Life Investment
Management Fee Series Fund, Inc., pays a fee equal on management and
an annual basis to .50% of its daily services
net assets.

The Putnam VT New Opportunities Fund Putnam Investment
pays a fee of 0.63% of its daily net management and
assets. services

The A I M V. I. Growth and Income Fund A I M Investment
pays a fee of 0.65% of its daily net management and
assets. services

The Equity, Income, Managed and IDS Life
Government Securities Portfolios of
IDS Life Series Fund, Inc. each pay a
fee equal on an annual basis to .70%
of their daily net assets.

The International Equity Portfolio of IDS Life
IDS Life Series Fund, Inc. pays a fee
on an annual basis equal to 0.95% of
its average daily net assets.

Non-Advisory IDS Life Series Fund, Inc. will IDS Life of New York Non-Advisory
Expense Charges reimburse IDS Life of New York for Expenses described
non-advisory expenses in Agreement
</TABLE>

(3) Distributions.

Not applicable. See paragraph (4) below.

(4) Cumulated or reinvested distributions or income.

All investment income and other distributions are reinvested in
Fund shares at net asset values.

(5) Redeemed or liquidated assets.

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

<PAGE>

(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.

(1) Amounts of payments to be made on certificates
(2) Amount of sales load
(3) Fee of custodian or trustee
(4) Insurance premium
(5) Other deductions from payments
(6) Total deductions (2 to 5)
(7) Net amount invested

Policies 1 and 2

See Item 13(a)(1).

(c) State (1) the amount of sales load as a percentage of the net amount
invested, and (2) the amount of total deductions as a percentage of
the net amount invested for each type of security issued by the trust.

Policy 1

(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) 3.5%. 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 2

(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: 1.0% of each premium payment.

Federal tax charge: 1.25% of each premium payment.

(d) Explain the reasons for any difference in the price at which
securities are offered generally to the public, and the price at
which securities are offered for any class of transactions to any
class or group of individuals, including officers, directors, or
employees of the depositor, trustee custodian or principal
underwriter.

Not applicable.

<PAGE>

(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 of New York 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
of New York for assuming certain mortality and expense risks
under the Policy.

IDS Life of New York 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 of New York 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 of New
York for amounts paid to Smith Barney on the sale of Trust units
to the Variable Account.

IDS Life of New York 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 of New York.

Policy 2

Mortality and expense risk insurance

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 of New York 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.

(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 of New
York, nor any affiliated person of IDS Life of New York, 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 (AEFC) a fee equal on an annual basis to
.25% (.50% for International) of the Fund's average net assets
for investment advice relative to the Fund under an Investment
Advisory Agreement between AEFC and IDS Life.

<PAGE>

As custodian of the underlying securities, American Express Trust
Company will receive certain fees indirectly from the Fund. The
fees will be comparable to the fees received by custodians which
hold the assets of other mutual funds.

(g) State the percentage that the aggregate annual charges and
deductions for maintenance and other expenses of the trust, bear
to the dividend and interest income from the trust property
during the period covered by the financial statements filed
herewith.

Not applicable.

(h) For life insurance company separate accounts registered as unit
investment trusts issuing variable life insurance contracts:

If proceeds from explicit sales loads will not cover the expected
costs of distributing the contracts, identify the source from
which the shortfall, if any, will be paid. If any shortfall is to
be made up from assets from the Insurance Company's general
account, disclose, if applicable, the extent to which any amounts
paid by the Insurance Company may consist, among other things, of
proceeds derived from mortality and expense risk charges deducted
from the account. If the level of the mortality and expense risk
charge is above the range of industry practice for comparable
variable life insurance contracts, disclose this fact along with
an explanation of why the charge is above this range, including
an identification of the factors used to calculate the charge. If
the level of the mortality and expense risk charge is above the
range of industry practice, also disclose the extent to which the
Insurance Company realizes positive cash flows (risk charge
proceeds net of current costs of meeting mortality and expense
guarantees) from risk charges, as well as the extent to which
positive cash flows may be used to pay distribution expenses. If
a portfolio company, selling its securities to the trust,
directly or indirectly pays distribution expenses under 1940 Act
Rule 12b-1, list the principal types of activities for which
payments are or will be paid; and (1) if the plan has been in
effect for a full fiscal year, give the total amount spent in
most recent fiscal year, as a percentage of net assets; or (2)
otherwise describe the basis on which payments will be made
(e.g., percentage of net assets, etc.). Disclose the extent, if
any, to which such a plan of distribution directly or indirectly
pays, or will pay, expenses of distributing the variable life
insurance contracts.

Any profit from the mortality and expense risk charge would be
available to IDS Life of New York 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 and surrender charges. Any further deficit will have to
be made up from IDS Life of New York'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.

<PAGE>

Policies 1 and 2

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

15. Policies 1 and 2

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.

16. Policies 1 and 2

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

The 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 of New York's Home Office underwriting department, the
premiums received by IDS Life of New York are held in IDS Life of New
York'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 of New York'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 of New York 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 of New York at
its Home Office. Fund shares or units of the Trust may be redeemed by IDS
Life of New York 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.

<PAGE>

Policies 1 and 2

Any surrender by an Owner may be made by a request in writing to the
Home Office of IDS Life of New York. IDS Life of New York 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 of New York at its Home Office, however IDS
Life of New York 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 not 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 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. If IDS Life of New York postpones
payment for more than 30 days, interest at an annual rate of 3 percent
will be paid on the amount surrendered for the period of postponement.

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

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

Policy 1

The Fund is required to redeem Fund shares at net asset value at the
request of IDS Life of New York, 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 of New York, and to make payment
therefor to the Variable Account within seven days of the receipt of
the redemption request.

Policy 2

<PAGE>

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.

Policy 1

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.

Policy 2

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.

(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 of New York does not intend to establish
any reserves for federal income taxes which may be attributable to the
Variable Account.

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

Not applicable.

19. Describe the procedure with respect to keeping of records and accounts of
the trust, the making of reports and the furnishing of information to
security holders, and the substance of the provisions of any indenture or
agreement pertaining thereto.

<PAGE>

IDS Life of New York has primary responsibility for all administration of
the Policy and will maintain the records and books of the Variable Account.

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

(a) Amendments to such indenture or agreement.

Not applicable.

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

Not applicable.

(c) The removal or resignation of the trustee or custodian, or the failure
of the trustee or custodian 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 of New York, 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

The Owner may obtain a loan from the Company be 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. 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 of New York will compute the Loan Value as of the end
of the Valuation Period during which the loan request is received at
its Home Office.

<PAGE>

The Loan Value of the Variable Account will be paid within seven days
after the Owner's written request is received by IDS Life of New York
at its Home Office, however IDS Life of New York 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 not 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 6 months from the date IDS Life of
New York receives the request. If IDS Life of New York postpones
payment more than 30 days, interest at an annual rate of 3 percent
will be paid on the amount loaned or surrendered for the period of
postponement.

Policy 2

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 or the remaining loan value, whichever is less.

Maximum loan: IDS Life of New York 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 of New York 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.

Payment of loaned funds: Generally, IDS Life of New York will pay
loans within seven days after IDS Life of New York receives the
owner's request (with certain exceptions - see "Deferral of
payments").

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 of New York will credit
the policy value loaned with 4% annual interest.

<PAGE>

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 of New York otherwise. Repayments must
be in amounts of at least $50.

Effects of Policy loans:

If the owner does not repay the loan, it will reduce the death benefit
and policy value. Even if the owner does repay it, the owner's 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 portfolios. A loan may terminate
the DBG-100 or the minimum initial premium period. The loan amount is
deducted from total premiums paid, which may reduce the total below
the level required to keep the DBG-100 or the minimum initial premium
period in effect.

Taxes: If the owner's policy lapses or the owner surrenders it with an
outstanding indebtedness, and the amount of outstanding indebtedness
plus the cash surrender value is more than the sum of premiums the
owner paid, the owner will generally be liable for taxes on the
excess.

Deferral of payments: IDS Life of New York 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 from the fixed account may be delayed up to six months from
the date IDS Life of New York receives the request. If IDS Life of New
York postpones the payment of loan or surrender proceeds more than 10
days, IDS Life of New York will pay the owner interest on the amount
loaned or surrendered at an annual rate of 4% 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 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.

<PAGE>

A loan from the subaccounts will result in accumulation units being
redeemed and the proceeds transferred from the subaccounts into IDS
Life of New York'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 of New York
otherwise.

If additional interest accrues to the Policy loan and is not paid when
due, IDS Life of New York 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 of New York 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.

Policy 2

Overdue interest: If accrued interest is not paid when due, IDS Life
of New York 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 of New
York 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 portfolios(s). A loan
may terminate 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-100 in effect.

IDS Life of New York will credit the loaned amount with 4.5% annual
interest.

<PAGE>

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

For Policy 1, the outstanding loan balance for fiscal year 1996 was
$7,301,682.65. No loans were in default for Policy 1.

Not applicable for Policy 2.

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

Not applicable.

23. Describe any bonding arrangement for officers, directors, partners or
employees of the depositor or principal underwriter of the trust, including
the amount of coverage and the type of bond.

The officers, employees and sales force of IDS Life of New York are bonded
in the amount of $100 million, by virtue of a blanket fidelity bond issued
to American Express Company by Saint Paul Fire and Marine, the leading
underwriter.

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 of New York, however, unless it is filed with IDS
Life of New York at its Home Office for recording.

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 of New York is a stock life insurance company organized under New
York in 1972.

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.

<PAGE>

Policy 1
<TABLE>
<CAPTION>

Aggregate
Total purchase Amount of Amount of gross amount
payments by Amount of administrations management Amount of of load, fees,
Year security sales load fees received fees received other fees etc. received
holders received received
- ----------------- ---------------- --------------- ---------------- ---------------- --------------- ----------------
<S> <C> <C> <C> <C> <C> <C>
1994 $8,111,811 $269,275 $2,634,696 $0 $0 $11,015,782
1995 8,347,157 464,724 3,170,655 0 0 11,982,536
1996 13,797,579 551,374 4,121,572 0 0 18,470,525
</TABLE>

Policy 2

Not applicable.

(b) The following information is furnished 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.

IDS Life of New York has entered into certain agreements with which it
is compensated by the advisors and/or distributors of AIM V.I. Growth
and Income Fund and Putnam VT New Opportunities Fund for the
administrative services it provides to these funds.

27. Describe the general character of the business engaged in by the depositor
including a statement as to any business other than that of depositor of
the trust. If the depositor acts or has acted in any capacity with respect
to any investment company or companies other than the trust, state the name
or names of such company or companies, their relationship, if any, to the
trust, and the nature of the depositor's activities therewith. If the
depositor has ceased to act in such named capacity, state the date of and
circumstances surrounding cessation.

IDS Life of New York conducts a conventional life insurance business in
addition to a variable annuity business. IDS Life of New York conducts this
business in the state of New York only.

IDS Life of New York is also the sponsor of other unit investment trusts
consisting of separate accounts funding variable life insurance and
variable annuities.

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 of New York, together with their
principal occupations during the last five years, are shown below.

<PAGE>

John C. Boeder
Vice president, Mature Market Group, AEFC, since March 1994; president
and chief operating officer, IDS Life of New York , from 1991 to 1994;
vice president and chief operating officer, IDS Life of New York, from
1989 to 1991.

Roger C. Corea
Group vice president, Upstate New York, AEFA, since January
1995; vice president, Northeast Region, AEFA, from May 1987 to
December 1994.

Charles A. Cuccinello
Retired since 1982; former senior vice president, American
Express Company.

Robert R. Grew
Lawyer and Partner, Carter, Ledyard & Milburn, NYC, 1957-present.

Robert A. Hatton
Vice president and chief operating officer, IDS Life of New
York since June 1994; special assignment/Project leader, AEFA,
December 1992 to June 1994; manager/Analyst operations, AEFA,
August 1989 to December 1992.

Richard W. Kling
President and chairman of the board, IDS Life of New York,
since April 1994; director, IDS Life, since February 1984;
President, IDS Life, since March 1994; executive vice
president, Marketing and Products, IDS Life, from January 1988
to March 1994; senior vice president, Risk Management
Products, AEFC, since May 1994; vice president, AEFC, from
January 1988 to May 1994; director and president of IDS Life
Series Fund, Inc.; chairman of the board of managers and
president of IDS Life Variable Annuity Funds A and B.

Edward Landes
Retired, former Development Consultants; director, IDS Life
Series Fund, Inc., since September 1985; member of the board
of Managers of IDS Life Variable Annuity Funds A and B since
October 1988. Director of IDS Life Insurance Company of New
York; vice president of Financial YMCA Development, YMCA,
since 1985.

Thomas V. Nicolosi
Director since October 1996; group vice president, AEFA, from
January 1995 to present; field vice president, AEFA, from
January 1988 to December 1994.

Stephen P. Norman
Secretary, American Express, since 1982.

Carl N. Platou
Retired since 1990; member of the board of directors, St.
Thomas University, since 1990; chief financial officer,
Fairview Hospital, from 1953 to 1990.

<PAGE>

Gordon H. Ritz
President, Con Rad Broadcasting Corporation (Minneapolis), since 1975.

Richard M. Starr
Director since October 1996; managing counsel, American
Express Company, since March 1995; senior counsel, American
Express Company, from May 1992 to March 1995; counsel,
American Express Company, from June 1989 to May 1992.

Michael R. Woodward
Senior vice president, Field Management, AEFC, since June
1991; region vice president, Atlantic Region, AEFC, from 1988
to June 1991.

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

Mario Alaia
Claims officer and assistant secretary since 1988.

Darrell C. Beckstrom
Underwriting officer since 1994; underwriting technical
manager, IDS Life, since 1990; senior underwriter, IDS Life,
from 1987 to 1992.

Eugene C. Chen
Chief actuary since November 1996; manager of Life Planning
and Analysis, AEFA, from May 1995 to November 1996; senior
staff actuary - Product Development Risk Management, IDS Life,
from August 1992 to May 1995.

Darlene S. Farron
Treasurer since June 1996; financial project manager - Finance
Department from September 1994 to June 1996; team leader of
Premium, Investment and External Reporting - Finance
Department from March 1988 to September 1994.

Donna M. Gaglione
Secretary since 1995; manager of Administrative Services since
1992; treasurer from 1985 to 1992.

Margaret M. Grogan, M.D.
Medical director since 1986.

Lorraine R. Hart
Investment officer since March 1992; vice president, Insurance
Investments, IDS Life, since October 1989.

F. Dale Simmons
Vice president and assistant treasurer since 1994; vice
president and senior portfolio manager, Insurance Investments,
AEFC, since 1990.

William A. Stoltzmann
Counsel and assistant secretary since March 1990.

<PAGE>

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 of New York is a wholly owned subsidiary of IDS Life Insurance
Company, a Minnesota corporation, which is itself 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.

Compensation of Officers and Directors of Depositor
Compensation of Officers of Depositor

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

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

To be filed by amendment.

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

To be filed by amendment.

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:

<PAGE>

To be filed by amendment.

(b) indirectly or through subsidiaries to directors:

To be filed by amendment.

Compensation to Employees

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

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 in
supervisory capacity; (3) administrative and clerical employees; and
(4) others (specify). If a person is employed in more than one
capacity, classify according to the predominant type of work.

Not applicable - see Item 31.

Compensation to Other Persons

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

Not applicable - see Item 31.

IV.

DISTRIBUTION AND REDEMPTION OF SECURITIES

Distribution of Securities

35. Furnish the names of the states in which sales of the trust's securities
(A) are currently being made, (B) are presently proposed to be made, and
(C) have been discontinued, indicating by appropriate letter the status
with respect to each state.

IDS Life of New York currently sells Policy 1 and intends to sell Policy 2
in New York only.

<PAGE>

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

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

<PAGE>

Variable Annuity and Life Insurance Distribution Agreement between
AEFA (formerly IDS Financial Services, Inc.) and IDS Life of New York.
Under this agreement, IDS Life of New York appoints AEFA to solicit
and procure, within the state of New York, applications for variable
life insurance policies. Sales compensation will be paid according to
compensation schedules published periodically. This agreement became
effective July 1, 1987 and may be terminated by mutual agreement of
the parties upon 30 days' notice.

(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 of New York will pay a commission of up to 47.5 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. Additional commissions will be paid if an
increase in coverage occurs. IDS Life of New York will also pay
approximately 27 percent of the total representative's commission to
the field vice presidents and district sales managers of the selling
representative.

Policy 2

To be filed by amendment.

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.

American Express Financial Advisors, Inc.
IDS Tower 10
Minneapolis, MN 55440

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

American Express Financial Advisors Inc. 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.

<PAGE>

Not applicable.

(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.

Not applicable.

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.

AEFA offers mutual funds, investment certificates and a broad range of
financial management services. AEFA serves individuals and businesses
through its nationwide network of more than 177 offices and more than
8,350 financial advisors.

(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.

Robert A. Hatton
VP and Chief Operating Officer
IDS Life of New York
20 Madison Ave. Ext.
Albany, NY 12203

(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 by such salesmen in such year.

Policy 1

There were 511 individual salesmen.

<PAGE>

Policy 2

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 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 of New York's home office underwriting department, the premiums
received by IDS Life of New York are held in IDS Life of New York'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 of New York'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 of New York 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 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 of
New York for the transaction charge which it has paid to Smith
Barney.

<PAGE>

The transaction charge is currently .25 percent on an annual
basis and is guaranteed to never exceed .50 percent.

Policy 2

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 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

<PAGE>

o any transfers to the subaccount (from the fixed account or
other subaccounts, including loan repayment transfers)
during the period; minus

o any transfers from the subaccount including loan transfers
during the current valuation period; minus

o any partial surrenders and partial surrender fees allocated
to the subaccount during the period; minus

o any portion of the monthly deduction allocated to the
subaccount during the period.

The net investment factor measures the investment performance of a
subaccount from one valuation period to the next. Because performance
may fluctuate, the value of a subaccount may increase or decrease from
day to day.

Accumulation units: The policy value allocated to each subaccount is
converted into accumulation units. Each time the owner directs a
premium payment or transfers policy value into one of the subaccounts,
a certain number of accumulation units are credited to their policy
for that subaccount. Conversely, each time they take a partial
surrender or transfer value out of a subaccount, a certain number of
accumulation units are subtracted.

Accumulation units are the true measure of investment value in each
subaccount. For subaccounts investing in the fund, they're related to,
but not the same as, the net asset value of the corresponding fund.
The dollar value of each accumulation unit can rise or fall daily,
depending on the investment performance of the underlying fund, 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 of New York 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

<PAGE>

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

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 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.

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

Policy 1

The cost of insurance for any given Policy will vary with age, sex and
health of the Insured.

Policy 2

No Policy has been offered for sale to the public.

(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.

Policy 1 and 2

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.

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:

<PAGE>

(a) by whose action redemption rights were suspended.

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

(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.
<PAGE>

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.

Policies 1 and 2

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

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 of New York will serve as custodian for the
Variable Account.

(b) Form of organization.

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

(d) Name of governmental supervising or examining authority.

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

<PAGE>

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.

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 Policies are provided by IDS Life of New
York.

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

Policy 1

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

Policy 2

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

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
the Policies, the company assumes the risks under the death benefit
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.

<PAGE>

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

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

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

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

Policy 1

The 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 of New
York. The minimum scheduled premium payment IDS Life of New York will
accept is $25. IDS Life of New York 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. The Company reserves the right to limit the number
and amount of unscheduled premiums. Currently, the maximum payment IDS
Life of New York will accept is $500,000.

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

<PAGE>

to comply with the law, IDS Life of New York 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.

(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 Data
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.

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 2

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 of New York requires that the owner pay the premium
minimum initial premium period in effect.

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

<PAGE>

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-100 or the minimum
initial premium period in effect.

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-100 or the minimum initial premium
period 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 of New York 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.

Allocation of premiums:

Until the policy date, IDS Life of New York holds all premiums in the
fixed account, and we credit interest on the net premiums (gross
premiums minus premium expense charge) at the current fixed account
rate. As of the policy date, IDS Life of New York will allocate the
net premiums plus accrued interest to the account(s) the owner has
selected in the owner's application. At that time, IDS Life of New
York will begin to assess the various loads, fees and charges.

Any amount allocated to a subaccount is converted into accumulation
units of that subaccount, as explained under "Policy Value."
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.

<PAGE>

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 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 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 minus partial surrenders minus
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 the DBG-100 is 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, 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

<PAGE>

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 Data, 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 years 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 the death benefit
guarantee 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 of New York 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 of New York receives
this premium before the end of the 61-day grace period, IDS Life of
New York 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.

(h) The amount of aggregate premiums paid to the insurance company during
the fiscal year.

Policy 1

In 1996, VUL-NY had contract premiums of $13,797,579. This is after
the premium expense charge, and other expenses.

Policy 2

No policy is currently being sold.

<PAGE>

(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.

Policy 1

IDS Life of New York deducts a sales charge and a charge for premium
taxes from each premium payment. The total of these charges is called
the Premium Expense Charge.

Sales Charge: A sales charge of 2.5% of each premium payment will be
deducted to compensate IDS Life of New York for expenses relating to
the distribution of the Policy, including agents' commissions,
advertising, and the printing of the prospectuses and sales
literature.

Premium Tax Charge: A charge of 1.0% of each premium payment will be
deducted to compensate IDS Life of New York for paying state premium
taxes imposed by the state of New York on premiums received by
insurance companies.

Also, deductions are made from the Policy Value after the premiums
have been allocated to the Subaccounts. However, no person other than
IDS Life of New York receives the amounts deducted for the mortality
and expense risk charge, the mortality charges, or the minimum death
benefit guarantee risk charge. IDS Life of New York may, from time to
time, enter into reinsurance treaties with other insurers whereby
these insurers may agree to reimburse IDS Life of New York for
mortality expenses. However, any such arrangements do not affect the
Policy.

Policy 2

IDS Life of New York deducts a sales charge and a charge for premium
taxes from each premium payment. The total of these charges is called
the Premium Expense Charge. IDS Life of New York deducts this charge
from each premium payment. The amount remaining after the deduction
called net premium, is credited to the account(s) you have selected.
The premium expense charge has three parts:

Sales Charge: A sales charge of 7.25% of all premiums paid. Partially
compensates IDS Life of New York for expenses in distributing the
Policy, including agents' commissions, advertising and printing of
prospectuses and sales literature.

Premium tax charge: 1.0% of each premium payment. Compensates IDS Life
of New York for paying taxes imposed by the State of New York on
premiums received by insurance companies.

Federal tax charges: 1.25% of each premium payment. Compensates IDS
Life of New York for paying Federal taxes resulting from the sale of
the policy and is a reasonable charge in relation to IDS Life of New
York's federal tax burden. IDS Life of New York reserves the right to
change the amount of this charge if applicable federal law changes IDS
Life of New York's federal tax burden subject to the approval of the
Superintendent of Insurance.

<PAGE>

(j) The substance of any other material provisions of any indenture or
agreement of the trust relating to insurance.

Not applicable.

VII .

POLICY OF REGISTRANT

52. (a) Furnish the substance of the provisions of any indenture or agreement
with respect to the conditions upon which and the method of selection
by which particular portfolio securities must or may be eliminated
from the assets of the trust or must or may be replaced by other
portfolio securities. If an investment adviser or other person is to
be employed in connection with such selection, elimination or
substitution, state the name of such person, the nature of any
affiliation to the depositor, trustee or custodian, and any principal
underwriter, and the amount of remuneration to be received for such
services. If any particular person is not designated in the indenture
or agreement, describe briefly the method of selection of such person.

If shares of any Fund Portfolio and/or units of the Trust should not
be available for purchase by the appropriate Subaccount or if, in the
judgment of IDS Life of New York'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 units of another unit investment trust may be
substituted for Fund shares or Trust units, respectively, held in the
Subaccount. If deemed by IDS Life of New York to be in the best
interest of persons having voting rights under the Policy, 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 of New York 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 or the insurance department of
the state of New York. IDS Life of New York will notify Owners within
five (5) days of any substitution or change.

(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;

<PAGE>

(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.

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 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 of New York's tax status and upon the tax status of the
individual concerned.

IDS Life of New York is taxed as a life insurance company under the
Code. Since the Variable Account is not a separate entity from IDS
Life of New York for tax purposes, and its operations form a part of
IDS Life of New York, 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 Internal
Revenue Code of 1954, and state its present intention with respect to
such qualification during the current taxable year.

Not applicable.

VIII .

FINANCIAL AND STATISTICAL INFORMATION

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

Not applicable.

<PAGE>

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 1

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 Cost of insurance rates and policy fees are - current rates and
fees for policies purchased before Mar 1, 1993 - guaranteed rates
and fees.

Any such illustration involves a number of detailed assumptions. (See
chart, "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 funds as
a whole but differed across individual funds.

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

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

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

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

<PAGE>

o the daily investment management fee paid by the funds, assumed to
be equivalent to an annual rate of 0.7% of the fund's 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 a nonadvisory expense charge of 0.1% of each fund's average daily
net assets for direct expenses incurred by the fund.

The nonadvisory expense charge for IDS Life Series Fund is capped by IDS
Life of New York at 0.1%, even though actual expenses on the IDS Life
Series Fund - Government Securities Portfolio ranged up to 0.18%, IDS Life
Series Fund - Money Market Portfolio ranged up to 0.23% and IDS Series Fund
- International Equity Portfolio ranged up to 0.37%. Although IDS Life of
New York reserves the right to discontinue capping these expenses, IDS Life
of New York's present intent is to continue the cap indefinitely until
actual expenses are less than the cap. Should IDS Life of New York
discontinue the cap prior to that time, the policy values and the death
benefits in the tables generally would be less. Other expenses for the
period ended Dec. 31, 1996 were 0.09% for Putnam VT New Opportunities Fund.
For AIM V.I. Growth and Income Fund other expenses (annualized) were 0.13%
for the period ended Dec. 31, 1996.

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 of New
York does not currently charge the subaccount for federal income tax. If
such a charge is taken in the future, the funds will have to earn more than
they do now in order to produce the death benefits and policy values
illustrated.

Illustration Policies purchased before May 1, 1993
- ---------------------------------------------------------------------------------------------------------------------
Initial specified amount Male age 35 Current costs assumed
$100,000 Death benefit nonsmoker annual premium $900
Option 1
- ---------------------------------------------------------------------------------------------------------------------
Premium Death benefit (1)(2) assuming Policy value (1)(2) assuming Cash surrender value (1)(2)
accumulated hypothetical gross annual hypothetical gross annual assuming hypothetical gross
with investment return of investment return of annual investment return of
End of annual
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 $ 618 $ 662 $ 705 $ 0 $ 14 $ 58
2 1,937 100,000 100,000 100,000 1,226 1,352 1,483 499 625 756
3 2,979 100,000 100,000 100,000 1,814 2,061 2,329 1,028 1,276 1,544
4 4,073 100,000 100,000 100,000 2,381 2,790 3,250 1,537 1,945 2,406
5 5,222 100,000 100,000 100,000 2,929 3,538 4,254 2,028 2,637 3,353

6 6,428 100,000 100,000 100,000 3,445 4,297 5,338 2,724 3,576 4,617
7 7,694 100,000 100,000 100,000 3,942 5,077 6,522 3,402 4,536 5,982
8 9,024 100,000 100,000 100,000 4,410 5,869 7,806 4,049 5,509 7,446
9 10,240 100,000 100,000 100,000 4,859 6,686 9,212 4,679 6,506 9,032
10 11,886 100,000 100,000 100,000 5,280 7,516 10,742 5,280 7,516 10,742

11 13,425 100,000 100,000 100,000 5,673 8,362 12,409 5,673 8,362 12,409
12 15,042 100,000 100,000 100,000 6,038 9,224 14,229 6,038 9,224 14,229
13 16,739 100,000 100,000 100,000 6,365 10,093 16,208 6,365 10,093 16,208
14 18,521 100,000 100,000 100,000 6,665 10,979 18,375 6,665 10,979 18,375
15 20,392 100,000 100,000 100,000 6,929 11,875 20,741 6,929 11,875 20,741

16 22,356 100,000 100,000 100,000 7,157 12,780 23,328 7,157 12,780 23,328
17 24,419 100,000 100,000 100,000 7,338 13,686 26,152 7,338 13,686 26,152
18 26,585 100,000 100,000 100,000 7,473 14,593 29,242 7,473 14,593 29,242
19 28,859 100,000 100,000 100,000 7,552 15,492 33,621 7,552 15,492 33,621
20 31,247 100,000 100,000 100,000 7,564 16,373 36,316 7,564 16,373 36,316

age 60 45,102 100,000 100,000 100,000 6,768 20,655 60,169 6,768 20,655 60,169
age 65 62,785 100,000 100,000 113,472 3,434 23,746 96,010 3,434 23,746 93,010

</TABLE>

(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.

Policies purchased on or after May 1, 1993
Illustration and before November 20, 1997
- ---------------------------------------------------------------------------------------------------------------------
Initial specified amount Male age 35 Current costs assumed
$100,000 Death benefit nonsmoker annual premium $900
Option 1
- ---------------------------------------------------------------------------------------------------------------------
Premium Death benefit (1)(2) assuming Policy value (1)(2) assuming Cash surrender value (1)(2)
accumulated hypothetical gross annual hypothetical gross annual assuming hypothetical gross
with investment return of investment return of annual investment return of
End of annual
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 $ 618 $ 662 $ 705 $ 0 $ 14 $ 58
2 1,937 100,000 100,000 100,000 1,226 1,352 1,483 503 628 760
3 2,979 100,000 100,000 100,000 1,814 2,061 2,329 1,032 1,279 1,547
4 4,073 100,000 100,000 100,000 2,381 2,790 3,250 1,540 1,949 2,409
5 5,222 100,000 100,000 100,000 2,929 3,538 4,254 2,029 2,639 3,355

6 6,428 100,000 100,000 100,000 3,456 4,308 5,350 2,735 3,587 4,629
7 7,694 100,000 100,000 100,000 3,965 5,101 6,547 3,424 4,560 6,007
8 9,024 100,000 100,000 100,000 4,452 5,914 7,854 4,091 5,554 7,494
9 10,420 100,000 100,000 100,000 4,915 6,747 9,279 4,735 6,567 9,099
10 11,886 100,000 100,000 100,000 5,352 7,598 10,833 5,352 7,598 10,833

11 13,425 100,000 100,000 100,000 5,763 8,467 12,529 5,763 8,467 12,529
12 15,042 100,000 100,000 100,000 6,149 9,356 14,384 6,149 9,356 14,384
13 16,739 100,000 100,000 100,000 6,508 10,263 16,411 6,508 10,263 16,411
14 18,521 100,000 100,000 100,000 6,837 11,188 18,628 6,837 11,188 18,628
15 20,392 100,000 100,000 100,000 7,134 12,128 21,053 7,134 12,128 21,053

16 22,356 100,000 100,000 100,000 7,397 13,082 23,707 7,397 13,082 23,707
17 24,419 100,000 100,000 100,000 7,625 14,050 26,615 7,625 14,050 26,615
18 26,585 100,000 100,000 100,000 7,811 15,027 29,800 7,811 15,027 29,800
19 28,859 100,000 100,000 100,000 7,952 16,008 33,291 7,952 16,008 33,291
20 31,247 100,000 100,000 100,000 8,042 16,992 37,120 8,042 16,992 37,120

age 60 45,102 100,000 100,000 100,000 7,565 21,792 62,844 7,565 21,792 62,844
age 65 62,785 100,000 100,000 128,223 4,981 25,956 105,101 4,981 25,956 105,101
</TABLE>

(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.

Illustration Policies purchased on or after November
20, 1997
- ----------------------------------------------------------------------------------------------------------------------
Initial specified amount Male age 35 Current costs assumed
$100,000 Death benefit nonsmoker annual premium $900
Option 1
- ----------------------------------------------------------------------------------------------------------------------
Premium Death benefit (1)(2) assuming Policy value (1)(2) assuming Cash surrender value (1)(2)
accumulated hypothetical gross annual hypothetical gross annual assuming hypothetical gross
with investment return of investment return of annual investment return of
End of annual
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 $ 621 $ 665 $ 709 $ 0 $ 7 $ 61
2 1,937 100,000 100,000 100,000 1,232 1,358 1,490 508 635 766
3 2,979 100,000 100,000 100,000 1,823 2,071 2,340 1,040 1,288 1,557
4 4,073 100,000 100,000 100,000 2,393 2,802 3,265 1,552 1,961 2,424
5 5,222 100,000 100,000 100,000 2,943 3,554 4,273 2,043 2,655 3,374

6 6,428 100,000 100,000 100,000 3,473 4,328 5,374 2,752 3,607 4,653
7 7,694 100,000 100,000 100,000 3,984 5,125 6,576 3,444 4,584 6,036
8 9,024 100,000 100,000 100,000 4,474 5,942 7,889 4,113 5,582 7,529
9 10,420 100,000 100,000 100,000 4,942 6,782 9,324 4,762 6,602 9,144
10 11,886 100,000 100,000 100,000 5,384 7,639 10,888 5,384 7,639 10,888

11 13,425 100,000 100,000 100,000 5,800 8,516 12,595 5,800 8,516 12,595
12 15,042 100,000 100,000 100,000 6,192 9,413 14,462 6,192 9,413 14,462
13 16,739 100,000 100,000 100,000 6,555 10,328 16,503 6,555 10,328 16,503
14 18,521 100,000 100,000 100,000 6,889 11,261 18,735 6,889 11,261 18,735
15 20,392 100,000 100,000 100,000 7,194 12,213 21,179 7,194 12,213 21,179

16 22,356 100,000 100,000 100,000 7,465 13,180 23,854 7,465 13,180 23,854
17 24,419 100,000 100,000 100,000 7,699 14,160 26,784 7,699 14,160 26,789
18 26,585 100,000 100,000 100,000 7,893 15,149 29,994 7,893 15,149 29,994
19 28,859 100,000 100,000 100,000 8,041 16,145 33,512 8,041 16,145 33,512
20 31,247 100,000 100,000 100,000 8,141 17,145 37,373 8,141 17,145 37,373

age 60 45,102 100,000 100,000 100,000 7,714 22,042 63,312 7,714 22,042 63,312
age 65 62,785 100,000 100,000 129,185 5,182 26,336 105,889 5,182 26,336 105,889
</TABLE>

(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.

Illustration
- ---------------------------------------------------------------------------------------------------------------------
Initial specified amount Male age 35 Guaranteed costs assumed
$100,000 Death benefit nonsmoker annual premium $900
Option 1
- ---------------------------------------------------------------------------------------------------------------------
Premium Death benefit (1)(2) assuming Policy value (1)(2) assuming Cash surrender value (1)(2)
accumulated hypothetical gross annual hypothetical gross annual assuming hypothetical gross
with investment return of investment return of annual investment return of
End of annual
policy interest
year at 5% 0% 6% 12% 0% 6% 12% 0% 6% 12%
- ---------------------------------------------------------------------------------------------------------------------

6 6,428 100,000 100,000 100,000 3,445 4,297 5,338 2,724 3,576 4,617
7 7,694 100,000 100,000 100,000 3,942 5,077 6,522 3,402 4,536 5,982
8 9,024 100,000 100,000 100,000 4,410 5,869 7,806 4,049 5,509 7,446
9 10,420 100,000 100,000 100,000 4,859 6,686 9,212 4,679 6,506 9,032
10 11,886 100,000 100,000 100,000 5,280 7,516 10,742 5,280 7,516 10,742

16 22,356 100,000 100,000 100,000 7,146 12,770 23,318 7,146 12,770 23,318
17 24,419 100,000 100,000 100,000 7,327 13,675 26,141 7,327 13,675 26,141
18 26,585 100,000 100,000 100,000 7,462 14,581 29,230 7,462 14,581 29,230
19 28,859 100,000 100,000 100,000 7,541 15,480 32,608 7,541 15,480 32,608
20 31,247 100,000 100,000 100,000 7,554 16,360 36,301 7,554 16,360 36,301

age 60 45,102 100,000 100,000 100,000 6,486 20,369 61,016 6,486 20,369 61,056
age 65 62,785 100,000 100,000 124,007 2,602 22,855 101,645 2,602 22,855 101,645
</TABLE>

(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.

Policy 2

No certificates are currently being sold.

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

Not applicable.

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

Not applicable.

<PAGE>

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 at the latest practicable date.

Not applicable.

59. Financial Statements:

Financial Statements of the Trusts

Financial Statements of the Accounts

The following audited financial statements of IDS Life of New York Account
8 (comprised of subaccounts YEQ, YIN, YMM, YMA, YGS, YIT, YGI and YNO) as
of December 31, 1997 are included in the Pre-effective Amendment No. 1 to
the Registration Statement on Form S-6 (File No. 333-42257) filed by the
Registrant the same date as the filing of Amendment No. 5 to this
Registration Statement. Upon such filing, these financial statements
together with the opinion of Ernst & Young LLP, independent public
accountants, will be incorporated herein by reference:

Statements of Net Assets as of Dec. 31, 1997; and

Statements of Operations and Changes in Net Assets for each of the three
years in the period ended Dec. 31, 1997, except for the YGI and YNO
subaccounts which are for the year ended Dec. 31, 1997 and the period Nov.
22, 1996 (commencement of operations) to Dec. 31, 1996.

Financial Statements of the Depositor

The following audited financial statement of IDS Life Insurance Company of
New York, together with the opinion of Ernst & Young LLP, independent
public accountants, are included in the Pre-effective Amendment No. 1 to
the Registration Statement on Form S-6 (File No, 333-42257) filed by the
Registrant pursuant to the Securities Act of 1933 on the same date as the
filing of Amendment No. 5 to this Registration Statement and upon such
filing, such statements will be incorporated herein by reference:

Statement of Net Assets as of Dec. 31, 1997; and

Statement of Operations as of Dec. 31, 1997; and

Statement of Changes in Net Assets as of Dec. 31, 1997; and

Notes to the Financial Statements.

<PAGE>

EXHIBITS

A. Copies of all exhibits required by paragraph A of instructions for Exhibits
to Form N-8B-2.

(1) Resolution of Board of Directors of IDS Life of New York authorizing
the Trust filed electronically as Exhibit 1.A.(1) to Registrant's Form
N-8B-2 Amendment No. 3. *

(2) Not applicable.

(3) (a) Not applicable.

(b) 1) Explanation of New York Sales Agreements. Filed as an
Exhibit 1 to Amendment No. 3 to the Registration Statement
to form N-8B-2 File No. 811-05213.*

2) Form of Personal Financial Planner's Agreement with IDS
Financial Services Inc. Filed as an Exhibit to Amendment No.
3 to the Registration Statement to form N-8B-2 File No.
811-05213.*

3) Form of Personal Financial Planner's Agreement with IDS Life
Insurance Company of New York. Filed as an Exhibit to
Amendment No. 3 to the Registration Statement to form N-8B-2
File No. 811-05213.*

4) Form of "Field Trainer's" Rider to Personal Financial
Planner's Agreement. Filed as an Exhibit to Amendment No. 3
to the Registration Statement to form N-8B-2 File No.
811-05213.*

5) Form of District Manager's Rider to Personal Financial
Planner's Agreement. Filed as an Exhibit to Amendment No. 3
to the Registration Statement to form N-8B-2 File No.
811-05213.*

6) Form of "New York District Manager-Insurance" Rider to
Personal Financial Planner's Agreement. Filed as an Exhibit
to Amendment No. 3 to the Registration Statement to form
N-8B-2 File No. 811-05213.*

7) Form of Division Manager's Agreement with IDS Financial
Services Inc. Filed as an Exhibit to Amendment No. 3 to the
Registration Statement to form N-8B-2 File No. 811-05213.*

8) Form of "New York Division Manager- Insurance" Rider to
Division Manager's Agreement with IDS Financial Services
Inc. Filed as an Exhibit to Amendment No. 3 to the
Registration Statement to form N-8B-2 File No. 811-05213.*

9) Form of Field President Agreement with American Express
Financial Advisors Inc. Filed as an Exhibit to Amendment No.
4 to the Registration Statement to form N-8B-2 File No.
811-05213. **

10) Form of Recruiting and Training Manager License Agreement
with IDS Life Insurance Company of New York. Filed as an
Exhibit to Amendment No. 4 to the Registration Statement to
form N-8B-2 File No. 811-05213. **

<PAGE>

11) Form of Group Vice President Agreement with American Express
Financial Advisors Inc. Filed as an Exhibit to Amendment No.
4 to the Registration Statement to form N-8B-2 File No.
811-05213. **

12) Form of IDS Paraplanner License Agreement with IDS Life
Insurance Company of New York. Filed as an Exhibit to
Amendment No. 4 to the Registration Statement to form N-8B-2
File No. 811-05213. **

13) Form of Variable Annuity and Life Insurance Distribution
Agreement. Filed as an exhibit to Amendment No. 4 to the
Registration Statement to form N-8B-2 File No. 811-05213. **

14) (a) Flexible Premium Variable Life Insurance Compensation:
IDS Life of New York. Filed as an Exhibit for Policy 1
to Amendment No. 3 to the Registration Statement to
form N-8B-2 File No. 811-05213.*

(b) Flexible Premium Survivorship Variable Life Insurance:
Schedules of Sales Commission are filed electronically
herewith.

(4) Not applicable.

(5) (a) Flexible Premium Variable Life Insurance Policy. Filed as an
Exhibit for Policy 1 to Amendment No. 3 to the Registration
Statement to form N-8B-2 File No. 811-05213.*

(b) Flexible Premium Survivorship Variable Life Insurance Policy
Filed as an Exhibit for Policy 2 to Amendment No. 4 to
Registration Statement to form N-8B-2 File No. 811-05213. **

(6) (a) Certificate of Incorporation of IDS Life of New York. Filed as an
Exhibit to Amendment No. 3 to the Registration Statement to form
N-8B-2 File No. 811-05213.*

(b) By-laws of IDS Life of New York. Filed as an Exhibit to Amendment
No. 3 to the Registration Statement to form N-8B-2 File No.
811-05213.*

(7) Not applicable.

(8) (a) Investment Management and Services Agreement between IDS Life
Insurance Company and IDS Life Series Fund, Inc. Filed as an
Exhibit to Amendment No. 3 to the Registration Statement to form
N-8B-2 File No. 811-05213.*

(b) Investment Advisory Agreement between IDS Life Insurance Company
and IDS. Filed as an Exhibit to Amendment No. 3 to the
Registration Statement to form N-8B-2 File No. 811-05213.*

<PAGE>

(c) Reference Trust Indenture among Shearson Lehman Brothers Inc.,
the Bank of New York and Standard & Poors Corporation relating to
the Shearson Lehman Brothers Stripped ("Zero Coupon") U.S.
Treasury Securities Fund. Standard Terms and Conditions of Trust
relating to the Shearson Lehman Brothers Stripped ("Zero Coupon")
U.S. Treasury Securities Fund. Filed as an Exhibit to Amendment
No. 3 to the Registration Statement to form N-8B-2 File No.
811-05213.*

(d) Standard Terms and Conditions of Trust relating to the Shearson
Lehman Brothers Stripped ("Zero Coupon") U.S. Treasury Securities
Fund. Filed as an Exhibit for Policy 1 to Amendment No. 3 to the
Registration Statement to form N-8B-2 File No. 811-05213.*

(e) Participation Agreement between AIM Variable Insurance Funds,
Inc., AIM Distributors, Inc., and IDS Life Insurance Company of
New York, on behalf of itself and its separate accounts and
American Express Financial Advisors Inc. Filed as an Exhibit to
Amendment No. 4 to the Registration Statement to form N-8B-2 File
No. 811-05213. **

(f) Participation Agreement between IDS Life Insruance Company of New
York and Putnam Capital Manager Trust and Putnam Mutual Funds
Corp. filed as an Exhibit to Amendment No. 4 to Registration
Statement to form N-8B-2 File No. 811-05213. **

(g) Copy of Addendum to Investment Advisory Agreement dated January
1, 1995 between IDS Life Insurance Company and American Express
Financial Corporation. Filed as an Exhibit to Amendment No. 4 to
the Registration Statement to form N-8B-2 File No. 811-05213. **

(h) Copy of Addendum to Investment Management and Services Agreement
dated October 28, 1994 between IDS Life Series Fund, Inc. and IDS
Life Insurance Company. Filed as an Exhibit to Amendment No. 4 to
the Registration Statement to form N-8B-2 File No. 811-05213. **

(9) None.

(10) (a) Application form for the Flexible Premium Variable Life Insurance
Policy.*

(b) Application form for Life and Disability Income Insurance filed
electronically as an Exhibit to Amendment No. 4 to the
Registration Statement to form N-8B-2 File No. 811-05213. **

(11) Description of Transfer and Redemption Procedures and Method of
Conversion to Fixed Benefit Policies. Filed as an Exhibit to Amendment
No. 3 to the Registration Statement to form N-8B-2 File No.
811-05213.*

<PAGE>

(12) Director's Power of Attorney dated March 12, 1997. Filed as an Exhibit
to Amendment No. 4 to the Registration Statement to form N-8B-2 File
No. 811- 05213. **

B. (1) Not applicable.

(2) Not applicable.

C. Not applicable.

* All of these exhibits are incorporated by reference to Amendment No. 3 to the
Registration Statement to form N-8B-2 File No. 811-05213.

**All of these exhibits are incorporated by reference to Amendment No. 4 to the
Registration Statement to form N-8B-2 File No. 811-05213.

<PAGE>

Pursuant to the requirements of the Investment Company Act of 1940, the
depositor of the Registrant has caused this Registration Statement to be duly
signed on behalf of the Registrant in Minneapolis, Minnesota on the 9th day of
April, 1998.

IDS LIFE OF NEW YORK ACCOUNT 8

BY IDS LIFE INSURANCE COMPANY
OF NEW YORK (Depositor)

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

By: __________________________
Mary Ellyn Minenko

Attest: __________________________
William A. Stoltzmann
Counsel and Assistant Secretary
IDS Life Insurance Company of New York

*Signed pursuant to Directors' Power of Attorney dated March 26, 1997 filed
electronically as an Exhibit to Amendment No. 4 to the Registration Statement to
form N-8b-2 File No. 811-05213.

Exhibit Index

Flexible Premium Survivorship Variable Life Insurance Policy
File No. 333-42257

Exhibit Description

A.3(b).14(b) NY Commission and production schedules

Section 7: NY Commission and production schedules
<TABLE>
<CAPTION>

Variable Second-to-Die Life Insurance (V2D)
<S> <C> <C>
- ------------------------------------ ----------------------------------- -----------------------------------
Persistency EAP Sales
-----------------------------------
Standard Qual. Calc. Benefit Plan
- ------------------------------------ ----------------- ----------------- -----------------------------------
87% o o o
- ------------------------------------ ----------------- ----------------- -----------------------------------

- ------------------------------------ ----------------------------------- -----------------------------------
Variable(s) Commission Production
- ------------------------------------ ----------------------------------- -----------------------------------
PERCENT OF PERCENT OF PREMIUMS PAID
PREMIUM UP TO PREMIUM PAID IN IN EXCESS OF
CATEGORY TARGET EXCESS OF TARGET TARGET X FACTOR TARGET X FACTOR
- ------------------------------------ ----------------- ----------------- ----------------- -----------------
All ages 50% 2.0% 28 1.1
- ------------------------------------ ----------------- ----------------- ----------------- -----------------

- --------------------------- --------------------------------------------------------------------------------
Variable(s) Client Service Commissions
- --------------------------- --------------------------------------------------------------------------------
YEAR COMMISSION PER $1,000 MARKET VALUE OF THE
AVERAGE QUARTERLY CASH VALUE*(LESS LOANS)
--------------------------------------------------------------------------------
PROPRIETARY ASSETS NONPROPRIETARY ASSETS
- --------------------------- ---------------------------------------- ---------------------------------------
1+ $1.25 $.75**
- --------------------------- ---------------------------------------- ---------------------------------------
</TABLE>

* Average quarterly cash value (less loans) is calculated by taking the cash
values from the previous and current quarter's consolidated statement and
dividing by two.
** Paid quarterly (i.e., $.3125 per $1,000 each quarter for proprietary assets
and $.1875 per $1,000 for nonproprietary assets). Quarterly service fee is
paid when the quarterly client Consolidated Statement is printed.

New Business Commissions

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

Client Service Commissions

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

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

COMMISSIONS PRODUCTION
- -----------------------------------------------------------
$8,000 X 50% = $4,000 $8,000 X 28 = 224,000

<PAGE>

b. If the target premium is $8,000 and a $10,000 premium is applied,
commissions and weighted production would be calculated as follows:

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

c. If the selling advisor in Examples a. and b. is a second-year advisor in
his or her 45th service period, Supplemental Commissions would be
calculated as follows (assumes the advisor is meeting PVS and FPR):

SUPPLEMENTAL COMMISSIONS
- --------------------------------------------------------------------------------
$4,040 (commissions earned) x 15% (Supplemental rate) = $606

TOTAL COMMISSIONS EARNED
- --------------------------------------------------------------------------------
$4,040 (commissions earned) + $606 (Supplemental Commissions = $4,646

Guidelines

1. Annualization

a. What are the criteria for annualization?

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

b. How is the compensation base determined?

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

<PAGE>

c. When does it annualize?

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

d. What is the maximum annualized compensation?

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

e. What causes adjustment?

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

2. Compensation timing

Compensation is credited after business is processed.

New Business:
Up to two business days for new business entries
Two to 60 business days for underwriting, depending on underwriting
requirements Up to five business days after underwriting to issue the
policy

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

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

Surrenders:
Four business days

<PAGE>

Death claims:
Seven calendar days

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

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

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

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

3. Exit/purchase transactions

Exit/purchase transaction rules apply only when IDS Life or IDS Life of New York
traditional life, Universal Life, Variable Second-to-Die Life, Variable
Universal Life or LP+ policy is surrendered or lapses and a Variable
Second-to-Die Life policy is purchased. When this occurs and the final premium
due date of the lapsed or surrendered policy is six months before or one year
after the corporate office receipt date of the new policy, compensation will be
adjusted.

If the lapsed or surrendered policy is not another Variable Universal Life or
Variable Second-to Die Life policy, the following rules apply:

New policies that result in the same amount of coverage as the lapsed or
surrendered policy will pay a conservation fee without weighted production. The
amount of the conservation will be an amount equal to 25% of normal commissions.

<PAGE>

Full commission and weighed production will be paid on any increased coverage
portion of the new policy.

If the lapsed or surrendered policy is another Variable Second-to Die Life
policy or Variable Universal Life, the following rules apply:

======================================= ========================================
Lapsed or surrendered policy base Conservation fee amount
plan-specified amount
- --------------------------------------- ----------------------------------------
$ 0 - 99,999 $100
100,000 - 349,999 200
350,000 + 400
- --------------------------------------- ----------------------------------------

Full commission and weighted production will be paid on any increased coverage
portion of the new policy.

Cash-value rollover premium dollars from life insurance policies to Variable
Second-to Die Life policies pay compensation. Full compensation will only be
paid on the rollover dollars used to fund the portion of the target premium or
MFYAP associated with the increased portion of coverage. No compensation is paid
on rollover dollars used to fulfill the target premium or MFYAP associated with
the even coverage portion of the new policy. Compensation is not credited on
loans or partial surrenders used to pay premiums on another policy. No excess
commissions are paid on cash-value rollovers.

4. Licenses required

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

<PAGE>

5. Persistency

The persistency standard for Variable Second-to-Die Life products sold is 87%.

6. Advisor/relative purchases

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

7. Reversals

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

8. Supplemental Commissions

For first-, second- and third-year advisors, Supplemental Commissions will be
credited at the following rates:

=================== ==================== =======================================
Service year Service period Highly fronted, some deferred*
- ------------------- -------------------- ---------------------------------------
1 1-26 35%
2 27-39 25
2 40-52 15
3 53-78 10
- ------------------- -------------------- ---------------------------------------

* These rates are a percentage of New Business Commissions

<PAGE>

Supplemental Commissions are credited based on the rate in effect at the time
the business was submitted and the first payment was received. For instance, if
you submit business while you are a first-year advisor but it is not issued
until you reach your second year, you will received Supplemental Commissions at
the first-year rate.

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