IDS LIFE OF NEW YORK ACCOUNT 8
N-8B-2/A, 2000-08-28
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                       SECURITIES AND EXCHANGE COMMISSION

                              WASHINGTON, DC 20549


                                 Amendment No. 6

                                   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.

                  Policy 1 - Flexible Premium Variable Life Insurance Policy

                  Policy 2 - Flexible Premium Variable Survivorship Life
                             Insurance Policy

                  Policy 3 - Flexible Premium Variable Life Insurance Policy
                             (VUL-3 NY)

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., 200 AXP Financial Center,
         Minneapolis, MN 55474, 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.

          Richard Thoresen and Elizabeth  Thoresen vs. AEFC,  American  Partners
          Life Insurance  Company,  American  Enterprise Life Insurance Company,
          American Centurion Life Assurance Company,  IDS Life Insurance Company
          and IDS Life Insurance Company of New York, was commenced in Minnesota
          State Court in October 1998. The action was brought by individuals who
          purchased an annuity in a qualified  plan. The plaintiffs  allege that
          the  sale  of  annuities  in  tax-deferred   contributory   retirement
          investment  plans (e.g.  IRA's) is never  appropriate.  The plaintiffs
          purport  to  represent  a class  consisting  of all  persons  who made
          similar  purchases.  The  plaintiffs  seek  damages in an  unspecified
          amount.

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

                                       II.

          GENERAL DESCRIPTION OF THE TRUST AND SECURITIES OF THE TRUST

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

<PAGE>

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

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

                  The Policies are of the registered type insofar as each Policy
                  is personal to the Owner, the records concerning the Owner are
                  maintained by IDS Life 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.

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

                  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  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

<PAGE>
                  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.

                  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:

<PAGE>

                    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.

                  Policy 3

                  The policy may be  returned  for any reason and the owner will
                  receive a full  refund of all  premiums  paid.  To do so,  the
                  owner  must  mail or  deliver  the  policy  to IDS Life of New
                  York's home office or their  financial  advisor with a written
                  request  for  cancellation  by the 10th day  after  they  have
                  received it.

                  On the date the request is postmarked or received,  the policy
                  will immediately be considered void from the start.

                  If the owner surrenders the policy or the policy lapses during
                  the first 10 policy  years  and in the 10 years  following  an
                  increase  in  specified  amount,  a  surrender  charge will be
                  assessed.

                  The surrender charge reimburses IDS Life of New York for costs
                  of issuing  the policy,  such as  processing  the  application
                  (primarily  underwriting) and setting up computer records.  It
                  also partially pays for commissions,  advertising and printing
                  the prospectus and sales literature.

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

                  If the owner surrenders part of the value of the policy,  they
                  will be  charged  $25  (or 2% of the  amount  surrendered,  if
                  less.) This fee is guaranteed not to increase for the duration
                  of the policy.

<PAGE>
                  The  owner  may  surrender  the  policy  in full or in part by
                  written or  telephone  request.  A surrender  request  will be
                  processed at the end of the valuation  period during which the
                  request  is  received.  IDS Life of New York may  require  the
                  owner to return the policy.

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

                  If the owner totally  surrenders the policy,  they 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 request is received.

                  After the first  policy  year,  the  owner may  surrender  any
                  amount  from  $500 up to 90% of the  policy's  cash  surrender
                  value.   (Partial  surrenders  by  telephone  are  limited  to
                  $50,000.) The owner will be charged a partial surrender fee.

                  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 we receive  the  request.  In
                  determining  these  proportions,  IDS Life of New  York  first
                  subtracts the amount of any outstanding  indebtedness from the
                  fixed account value.

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

                  Policy 1

                  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.  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.

<PAGE>
                  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:

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

                  (b)      the next most recent increases successively; and

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

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

                  IDS Life 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.

<PAGE>
                  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).

                  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.

<PAGE>
                  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.

                    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     transfers     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.

                  Policy 3

                  Effect of partial surrenders:

                    o    A partial surrender will reduce the policy value by the
                         amount of the partial surrender and fee.

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

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

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

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

                  Because they reduce the specified amount,  partial  surrenders
                  may  affect the cost of  insurance.  IDS Life 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,  IDS Life of New York  will  process  the  transfer
                  request at the end of the  valuation  period  during  which it
                  receives the request. 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.
                  Transfers  involving  the fixed  account  are  subject  to the
                  restrictions below.

<PAGE>
                  Fixed Account Transfer Policies

                    o    Transfers  from the fixed account must be made during a
                         30-day period starting on a policy anniversary,  except
                         for  automated  transfers,  which  can be set up at any
                         time for transfer  periods the owner chooses subject to
                         certain minimums.
                    o    If IDS  Life  of New  York  receives  your  request  to
                         transfer  amounts 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 IDS Life of New
                         York  receives  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,  the  owner 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 you  exercise  the  policy's  right to
                         exchange provision.

                  Minimum Transfer Amounts

                  From a subaccount to another subaccount or the fixed account:

                    o    For  mail  and  phone  transfers--$250  or  the  entire
                         subaccount balance, whichever is less.
                    o    For automated transfers--$50.

                  From the fixed account to a subaccount:

                    o    $250 or the entire  fixed  account  balance,  minus any
                         outstanding indebtedness, whichever is less.
                    o    For automated transfers -- $50.

                  Maximum Transfer Amounts

                  From a subaccount to another subaccount or the fixed account:

                    o    None.

                  From the fixed account to a subaccount:

                    o    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 five per policy year. Twelve automated
                  transfers per policy year are allowed.

                  Two Ways to Request a Transfer, Loan or Surrender

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

<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,
                         mail procedure is an alternative.

                    o    IDS Life of New York will honor any telephone  transfer
                         or surrender  request believed to be authentic and will
                         use reasonable  procedures to confirm that it is. These
                         procedures  include  asking  identifying  questions and
                         tape recording  calls. As long as these  procedures are
                         followed,  IDS Life of New York and its affiliates will
                         not be liable for any loss  resulting  from  fraudulent
                         requests.

                    o    Telephone  transfers are available  automatically.  The
                         owner may request that telephone  transfers not be made
                         from their account by writing to IDS Life of New York.

                  Automated Transfers

                  In addition to written and telephone  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 amount: $50
                    o    Only  one  automated  transfer  arrangement  can  be in
                         effect at any time. Policy values may be transferred to
                         one or more subaccounts and the fixed account,  but can
                         be transferred from only one account.
                    o    The owner can start or stop  this  service  by  written
                         request. They must allow seven days for IDS Life of New
                         York to change any  instructions  that currently are in
                         place.
                    o    The owner  cannot  make  automated  transfers  from the
                         fixed account in an amount that,  if  continued,  would
                         deplete the fixed account within 12 months.
                    o    If the owner makes 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.

<PAGE>

                    o    If the request is submitted with an  application  for a
                         policy,  automated transfers will not take effect until
                         the policy is issued.
                    o    If the value of the account from which the policy value
                         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.

                  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,  the owner may
                  transfer  all of the policy  value in the  subaccounts  to the
                  fixed account.  IDS Life of New York automatically will credit
                  all future  premium  payments to the fixed account  unless the
                  owner requests a different allocation.

                  A  transfer  for this  purpose  will  not  count  against  the
                  five-transfers-per-year   limit.  Also,  any  restrictions  on
                  transfers  into the fixed  account  for this type of  transfer
                  will be waived.
                  There is no effect on the policy's  death  benefit,  specified
                  amount, net amount at risk, risk  classification 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.

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

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

                  A death  benefit  guarantee  charge is included in the monthly
                  deduction  in  the  first  five  policy  years  or  until  the
                  insured's attained age 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.

<PAGE>

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

                  If the  owner  wishes  to pay 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.

                  Policy 3

                  Keeping The Policy in Force

                  No lapse guarantee (NLG)

                  The NLG  provides  that your  policy  will remain in force for
                  five  policy  years,  even  if the  cash  surrender  value  is
                  insufficient to pay the monthly  deduction.  The NLG will stay
                  in effect as long as:

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

                  The minimum monthly premium is shown in the policy.

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

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

                  Grace period

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

                  IDS Life of New York will mail a notice  to the  owner's  last
                  known  address,  requesting  payment of the premium  needed so
                  that it can make the next  three  monthly  deductions.  If IDS
                  Life of New York receives  this premium  before the end of the
                  61-day  grace  period,  it will use the  payment  to cover all
                  monthly deductions and any other charges then due. IDS Life of
                  New York will add any balance to the policy value and allocate
                  it in the same manner as other premium payments.

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

                  Reinstatement

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

<PAGE>


                    o    a written request;
                    o    evidence  satisfactory to IDS Life of New York that the
                         insured remains insurable;
                    o    payment of the required reinstatement premium; and
                    o    payment or reinstatement of any indebtedness.

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

                  The effective date of a reinstated  policy will be the monthly
                  date on or next following the day IDS Life of New York accepts
                  the application for reinstatement. Surrender charges will also
                  be reinstated.

                  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.

                  Each share of a portfolio has one vote.  On some issues,  such
                  as the  election  of  directors,  all  shares of the Fund vote
                  together as one series. All shares have cumulative voting when
                  voting on the election of directors.  With cumulative  voting,
                  each shareholder is entitled to a number of votes equal to the
                  number of shares that the shareholder  holds multiplied by the
                  number of directors to be elected, and has the right to divide

<PAGE>
                    votes among  candidatesin  any way. On an issue  affecting a
                    particular portfolio,  its shares vote as a separate series.
                    An  example  of  such  an  issue  would  be  a   fundamental
                    investment restriction pertaining to only one portfolio.  In
                    voting on the Investment  Management and Services Agreement,
                    approval  of  the  Agreement  by  the   shareholders   of  a
                    particular  portfolio would make the Agreement  effective as
                    to that  portfolio,  whether or not it had been  approved by
                    the shareholders of the other portfolios.

                    As  previously  stated,  all  of  the  assets  held  in  the
                    subaccounts will be invested in shares of the  corresponding
                    portfolio or in units of the Trust. With regard to the Fund,
                    IDS Life 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.

                  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

<PAGE>
                  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.

                  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.

                  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.

                  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

<PAGE>
                  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.

                  Policy 3

                  The Variable account is comprised of various subaccounts.  The
                  subaccounts, the commencement dates of the subaccounts and the
                  portfolios they invest in are outlined in the table below.

Subaccount               Investing in:

                         IDS Life Series Fund -
Equity                   Equity Portfolio (8/87) 1
Equity Income            Equity Income Portfolio (9/00)1
Government Securities    Government Securities Portfolio (8/87) 1
Income                   Income Portfolio (8/87) 1
International Equity     International Equity Portfolio (10/94) 1
Managed                  Managed Portfolio (8/87) 1
Money Market             Money Market Portfolio (8/87) 1

                         AXPSM Variable Portfolio -
YBC                         Blue Chip Advantage Fund (9/00) 1
YBD                         Bond Fund (9/00) 1
YCR                         Capital Resource Fund (9/00) 1
YCM                         Cash Management Fund (9/00) 1
YDE                         Diversified Equity Income Fund (9/00) 1
YEM                         Emerging Markets Fund (9/00) 1
YEX                         Extra Income Fund (9/00) 1
YFI                         Federal Income Fund (9/00) 1
YGB                         Global Bond Fund (9/00) 1
YGR                         Growth Fund (9/00) 1
YIE                         International Fund (9/00) 1
YMF                         Managed Fund (9/00) 1
YND                         New Dimensions Fund(R)(9/00) 1
YIV                         S&P 500 Index Fund (9/00) 1
YSM                         Small Cap Advantage Fund (9/00) 1
YSA                         Strategy Aggressive Fund (9/00) 1

                         AIM V.I.
YCA                         Capital Appreciation Fund (9/00) 1
YCD                         Capital Development Fund (9/00) 1
YGI                         Growth and Income Fund (11/96) 1

                         American Century VP
YIR                         International (9/00) 1
YVL                         Value (9/00) 1

                         Calvert CVS
YSB                         Social Balanced Portfolio (9/00) 1

                         Fidelity VIP
YGC                         III Growth & Income Portfolio (Service
                            Class) (9/00) 1
YMP                         III Mid Cap Portfolio (Service Class)
                            (9/00) 1
YOS                         Overseas Portfolio (Service Class)
                            (9/00) 1
                         FTVIPT
YRE                         Franklin Real Estate Fund - Class 2
                            (9/00) 1
YSV                         Franklin Value Securities Fund  - Class
                            2 (9/00) 1
YIF                         Templeton International Securities Fund
                            - Class 2 (9/00) 1
YIS                         Templeton International Smaller
                            Companies Fund -
                            Class 2 (9/00) 1

                         Goldman Sachs VIT
YSE                         CORESM Small Cap Equity Fund (9/00) 1
YUE                         CORESM U.S. Equity Fund (9/00) 1

<PAGE>

YMC                         Mid Cap Value Fund (9/00) 1

                         Janus Aspen Series
YAG                         Aggressive Growth Portfolio: Service
                            Shares (9/00) 1
YGT                         Global Technology Portfolio: Service
                            Shares (9/00) 1
YIG                         International Growth Portfolio: Service
                            Shares (9/00) 1

                         Lazard Retirement Series
YIP                         International Equity Portfolio (9/00) 1

                         MFS(R) VIT
YGW                         Growth Series - Service Class (9/00) 1
YDS                         New Discovery Series - Service Class
                            (9/00) 1

                         Putnam Variable Trust
YPH                         Putnam VT High Yield - Class IB Shares
                            (9/00) 1
YIO                         Putnam VT International New
                            Opportunities Fund - Class IB Shares
                            (9/00) 1
YNO                         Putnam VT New Opportunities Fund -
                            Class IA Shares (11/96) 1
YVS                         Putnam VT Vista Fund - Class IB Shares
                            (9/00) 1

                         Royce
YMI                         Micro-Cap Portfolio (9/00) 1

                         Third Avenue
YVA                         Value Portfolio (9/00) 1

                         Wanger
YIC                         International Small Cap (9/00) 1
YSP                         U.S. Small Cap (9/00) 1

                         Warburg Pincus Trust
YEG                      Emerging Growth Portfolio (9/00) 1
YSC                      Small Company Growth Portfolio (9/00) 1

1        (Commencement date of the subaccount)

                  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.

                  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>
                  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.

          (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.

                  (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.

<PAGE>

                  (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 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.

<PAGE>
                  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.

                  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.

<PAGE>
                  Also, in order to receive  favorable  tax treatment  under the
                  Code,  premiums  paid  during the life of the policy  must not
                  exceed certain limitations.  To comply with the Code, IDS Life
                  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.

                  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:

<PAGE>

                    o    the policy value plus the specified amount; or

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

                  Policy 3

                  Payment of premiums:
                  In  applying  for the  policy,  the owner must decide how much
                  they  intend  to pay and how often  they  will make  payments.
                  During the first  several  policy years until the policy value
                  is sufficient to cover the surrender  charge,  IDS Life of New
                  York requires  that the owner pay premiums  sufficient to keep
                  the NLG in effect in order to keep the policy in force.

                  The owner may  schedule  payments  annually,  semiannually  or
                  quarterly.  (IDS Life of New York must approve  payment at any
                  other  interval).  IDS Life of New  York  shows  this  premium
                  schedule in the policy.

                  The  scheduled  premium  serves only as an  indication  of the
                  owner's  intent  as to the  frequency  and  amount  of  future
                  premium  payments.   The  owner  may  skip  scheduled  premium
                  payments at any time if the cash surrender value is sufficient
                  to pay the monthly  deduction or if  sufficient  premiums have
                  been paid to keep the no lapse guarantee in effect.

                  The  owner  may  also  change  the  amount  and  frequency  of
                  scheduled premium payments by written request. IDS Life 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 the  payments  will affect the policy
                  value, cash surrender value and length of time the policy will
                  remain in force,  as well as affect whether the NLG remains in
                  effect.

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

                  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 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) selected in the application.  At that time, IDS
                  Life of New York will begin to assess the various loads, fees,
                  charges and expenses.

<PAGE>
                  IDS Life of New  York  converts  any  amount  that  the  owner
                  allocates  to a  subaccount  into  accumulation  units of that
                  subaccount.  Similarly, when the owner transfers value between
                  subaccounts,  IDS Life of New York converts accumulation units
                  in one  subaccount  into a cash  value,  which IDS Life of New
                  York  then  converts  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
                  person  whose  life the owner  proposes  to  insure  (owner or
                  someone else). The underwriting  department of IDS Life of New
                  York will review the application  and any medical  information
                  or other data  required  to  determine  whether  the  proposed
                  individual  is insurable  under its  underwriting  rules.  The
                  application may be declined if IDS Life of New York determines
                  the  individual is not insurable and IDS Life of New York will
                  return any premium paid.

                  Age  limit:  IDS Life of New York  generally  will not issue a
                  policy where the proposed insured is over the insurance age of
                  80. It may, however, do so at its sole discretion.

                  Proceeds Payable Upon Death

                  IDS Life of New York will pay a benefit to the  beneficiary of
                  the policy when the insured dies.

                  If that  death is  prior  to the  maturity  date,  the  amount
                  payable is based on the  specified  amount  and death  benefit
                  option (described below) that the owner has selected, less any
                  indebtedness.

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

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

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

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

                    o    the policy value plus the specified amount; or
                    o    the  applicable  percentage of policy value on the date
                         of the  insureds  death,  if  that  death  occurs  on a
                         valuation date, or on the next valuation date following
                         the date of death.

Information Concerning the Securities Underlying the Trust's Securities

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

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

<PAGE>

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

         (a)      Name of Company.

                           IDS Life Series Fund, Inc1, 2, 3
                           The Shearson Lehman Brothers Fund of Stripped
                           ("Zero Coupon") U.S. Treasury
                           Securities Fund, Series A ("Zero Coupon Trust" -
                           a unit investment Trust).1
                           American  Express(R)  Variable  Portfolio  Funds3
                           AIM Variable  Insurance  Funds,   Inc.1,  2,  3
                           American Century Variable  Portfolios,  Inc.3
                           Calvert Variable Series,  Inc.3
                           Fidelity Variable Insurance  Products, Service
                           Products3
                           Franklin Templeton Variable Insurance Products
                           Trust3
                           Goldman Sachs Variable Insurance Trust3
                           Janus Aspen Series3
                           Lazard Retirement Series, Inc.3
                           MFS Variable Insurance Trust3
                           Putnam Variable Trust1,  2, 3
                           Royce Capital Fund3
                           Third Avenue Variable Series Trust3
                           Wanger Advisors Trust3
                           Warburg Pincus Trust3

                           1Applies to Policy 1
                           2Applies to Policy 2
                           3Applies to Policy 3

         (b)      Name and principal address of depositor.

                  Investment manager of IDS Life Series Fund, Inc.:
                  IDS Life Insurance Company
                  70100 AXP Financial Center
                  Minneapolis, MN 55474

                  Investment manager of American Express(R)Variable Portfolio
                  Funds:
                  IDS Life Insurance Company
                  70100 AXP Financial Center
                  Minneapolis, MN 55474

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

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

<PAGE>
                  Investment adviser of Calvert Variable Series, Inc.:
                  Calvert Asset Management Company, Inc.
                  4550 Montgomery Avenue
                  Suite 100 N
                  Bethesda, MD 20814

                  Investment subadviser:
                  NCM Capital Management Group, Inc.
                  103 West Main Street
                  Durham, NC 27701

                  Investment manager of Fidelity Variable Insurance Products:
                  Fidelity Management and Research (FMR) U.K. Inc.
                  London, England

                  Investment manager of Templeton Variable Products Series Fund:
                  Templeton Investment Counsel, Inc.
                  Broward Financial Center
                  Suite 2100
                  Fort Lauderdale, FL 33394

                  Investment adviser of Goldman Sachs Variable Insurance Trust:
                  Goldman Sachs Asset Management
                  32 Old Slip
                  New York, NY 10005

                  Investment adviser of Janus Aspen Series:
                  Janus Capital
                  100 Fillmore Street
                  Denver, CO 80206-4928

                  Investment manager of Lazard Retirement Series, Inc.:
                  Lazard Asset Management
                  30 Rockefeller Plaza
                  New York, NY 10112

                  Investment adviser of MFS Variable Insurance Trust:
                  Massachusetts Financial Service Company
                  500 Boyland Street
                  Boston, MA 02116

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

                  Investment adviser of Royce Capital Fund:
                  Royce & Associates Inc.
                  1414 Avenue of the Americas
                  New York, NY 10019

                  Investment adviser of Third Avenue Variable Trust:
                  EQSF Advisers, Inc.
                  767 Third Avenue
                  New York, NY 10017-2023

<PAGE>
                  Investment adviser of Wanger Advisors Trust:
                  Wanger Asset Mangement, L.P.
                  227 West Monroe Street
                  Suite 3000
                  Chicago, IL 60606

                  Investment adviser of Warburg Pincus Trust:
                  Credit Suisse Asset Mangement, LLC
                  One Citicorp Center
                  153 East 53rd Street
                  New York, NY 10022

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

                  For IDS Life Series Fund, Inc.
                  American Express Trust Company
                  200 AXP Financial Center
                  Minneapolis, MN  55474

                  Sponsor of the Zero Coupon Trust:
                  The Bank of New York
                  101 Barclay Street
                  New York, NY 10286

                  For American Express(R) Variable Portfolio Funds:
                  American Express Trust Company
                  200 AXP Financial Center
                  Minneapolis, MN 55474

                  For A I M Variable Insurance Funds, Inc.:
                  State Street Bank & Trust Co.
                  225 Franklin Street
                  Boston, MA 02110

                  For American Century Variable Portfolios, Inc.:
                  Chase Manhattan Bank
                  770 Broadway 10th Floor
                  New York, NY 10003-9598

                  For Calvert Variable Series, Inc.:
                  State Street Bank and Trust Co.
                  225 Franklin Street
                  Boston, MA 02110

                  For Fidelity Variable Insurance Products:
                  The Bank of New York
                  110 Washington Street
                  New York, NY 10286

                  For Templeton Variable Products Series Fund:
                  Bank of New York
                  Mutual Funds Division
                  90 Washington Street
                  New York, NY 10286

<PAGE>
                  For Goldman Sachs Variable Insurance Trust:
                  State Street Bank and Trust Co.
                  225 Franklin Street
                  Boston, MA 02110

                  For Janus Aspen Series:
                  State Street Bank and Trust Co.
                  P.O. Box 0351
                  Boston, MA 02117-0351

                  For Lazard Retirement Series, Inc.:
                  State Street Bank and Trust Co.
                  225 Franklin Street
                  Boston, MA 02110

                  For MFS Variable Insurance Trust:
                  State Street Bank and Trust Co.
                  225 Franklin Street
                  Boston, MA 02110

                  For Putnam Variable Trust:
                  Putnam Fiduciary Trust Company, a wholly-owned subsidiary of
                  Putnam Investments, Inc.
                  One Post Office Square
                  Boston, MA 02109

                  For Royce Capital Fund:
                  State Street Bank and Trust Co.
                  225 Franklin Street
                  Boston, MA 02110

                  For Third Avenue Variable Trust Series:
                  Custodial Trust Company
                  101 Carnegie Center
                  Princeton, NJ 08540-6231

                  For Wanger Advisors Trust:
                  State Street Bank and Trust Co.
                  P.O. Box 8502
                  Boston, MA 02266-8502

                  For Warburg Pincus Trust:
                  PNC Bank, National Association
                  200 Stevens Drive
                  Suite 440
                  Lester, PA 02171
                  and Commerce Bank, N.A.
                  1000 Walnut
                  Kansas City, MO 64105

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

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

<PAGE>

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

                  The  commencement  dates of the subaccounts are set out in the
                  table below.

Subaccount               Investing in:

                         IDS Life Series Fund -
Equity                   Equity Portfolio (8/87) 1
Equity Income            Equity Income Portfolio (9/00)1
Government Securities    Government Securities Portfolio (8/87) 1
Income                   Income Portfolio (8/87) 1
International Equity     International Equity Portfolio (10/94) 1
Managed                  Managed Portfolio (8/87) 1
Money Market             Money Market Portfolio (8/87) 1

                         AXPSM Variable Portfolio -
YBC                         Blue Chip Advantage Fund (9/00) 1
YBD                         Bond Fund (9/00) 1
YCR                         Capital Resource Fund (9/00) 1
YCM                         Cash Management Fund (9/00) 1
YDE                         Diversified Equity Income Fund (9/00) 1
YEM                         Emerging Markets Fund (9/00) 1
YEX                         Extra Income Fund (9/00) 1
YFI                         Federal Income Fund (9/00) 1
YGB                         Global Bond Fund (9/00) 1
YGR                         Growth Fund (9/00) 1
YIE                         International Fund (9/00) 1
YMF                         Managed Fund (9/00) 1
YND                         New Dimensions Fund(R)(9/00) 1
YIV                         S&P 500 Index Fund (9/00) 1
YSM                         Small Cap Advantage Fund (9/00) 1
YSA                         Strategy Aggressive Fund (9/00) 1

                         AIM V.I.
YCA                         Capital Appreciation Fund (9/00) 1
YCD                         Capital Development Fund (9/00) 1
YGI                         Growth and Income Fund (11/96) 1

                         American Century VP
YIR                         International (9/00) 1
YVL                         Value (9/00) 1

                         Calvert CVS
YSB                         Social Balanced Portfolio (9/00) 1

                         Fidelity VIP
YGC                         III Growth & Income Portfolio (Service
                            Class) (9/00) 1
YMP                         III Mid Cap Portfolio (Service Class)
                            (9/00) 1
YOS                         Overseas Portfolio (Service Class)
                            (9/00) 1
                         FTVIPT
YRE                         Franklin Real Estate Fund - Class 2
                            (9/00) 1
YSV                         Franklin Value Securities Fund  - Class
                            2 (9/00) 1
YIF                         Templeton International Securities Fund
                            - Class 2 (9/00) 1
YIS                         Templeton International Smaller
                            Companies Fund -
                            Class 2 (9/00) 1

                         Goldman Sachs VIT
YSE                         CORESM Small Cap Equity Fund (9/00) 1
YUE                         CORESM U.S. Equity Fund (9/00) 1
YMC                         Mid Cap Value Fund (9/00) 1

                         Janus Aspen Series
YAG                         Aggressive Growth Portfolio: Service
                            Shares (9/00) 1
YGT                         Global Technology Portfolio: Service
                            Shares (9/00) 1

<PAGE>

YIG                         International Growth Portfolio: Service
                            Shares (9/00) 1

                         Lazard Retirement Series
YIP                         International Equity Portfolio (9/00) 1

                         MFS(R) VIT
YGW                         Growth Series - Service Class (9/00) 1
YDS                         New Discovery Series - Service Class
                            (9/00) 1

                         Putnam Variable Trust
YPH                         Putnam VT High Yield - Class IB Shares
                            (9/00) 1
YIO                         Putnam VT International New
                            Opportunities Fund - Class IB Shares
                            (9/00) 1
YNO                         Putnam VT New Opportunities Fund -
                            Class IA Shares (11/96) 1
YVS                         Putnam VT Vista Fund - Class IB Shares
                            (9/00) 1

                         Royce
YMI                         Micro-Cap Portfolio (9/00) 1

                         Third Avenue
YVA                         Value Portfolio (9/00) 1

                         Wanger
YIC                         International Small Cap (9/00) 1
YSP                         U.S. Small Cap (9/00) 1

                         Warburg Pincus Trust
YEG                      Emerging Growth Portfolio (9/00) 1
YSC                      Small Company Growth Portfolio (9/00) 1

1        (Commencement date of the subaccount)

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.
<PAGE>
<TABLE>
<CAPTION>

                  Policy 1

                  (1)      Principal Payments.


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

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 and   if policy is surrendered within 5                                          Underwriting
Administrative       years of policy issue, decreasing                                          Expenses at Issue
Expense Charge       monthly thereafter at a rate of 20%
(Issue)              per year

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

<PAGE>


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
</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>
<TABLE>
<CAPTION>
                  Policy 2

                  (1)      Principal Payments.


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

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

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

<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 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>
<TABLE>
<CAPTION>
                           Policy 3

(1)      Principal Payments.


 Nature of Charge                    Amount                   Person to whom Paid/Relationship        Services
 ----------------                    ------                   --------------------------------        --------
<S>                <C>                                      <C>                               <C>
Premium Expense      3.5 % of premiums payment.               IDS Life of New York              Distribution of
Charge                                                                                          policy; State and
                                                                                                governmental taxes

Policy Fee           $5 per month.                            IDS Life of New York              Administrative
                                                                                                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 Riders  determined by nature IDS Life of New York
                     and amount of IDS Life Optional  Insurance  riders attached
                     to policy.

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

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

<PAGE>

                  (2)      Underlying Security

The  investment  managers  and advisers  receive fees for their  services to the
funds. The funds also pay taxes, brokerage commissions and nonadvisory expenses,
such as  custodian  and trustee  fees,  registration  fees for shares,  postage,
fidelity and security bond costs,  legal fees and other  miscellaneous  fees and
charges.  The table below sets out the  expenses  that the funds pay. The annual
operating  expenses are  calculated  as a percentage of average daily net assets
and paid to the  investment  managers and advisers as set forth in the answer to
question 11(b).

<TABLE>
<CAPTION>

                                                           Management         12b-1            Other
                                                           Fees               Fees             Expenses        Total
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
<S>                                                      <C>                <C>              <C>             <C>
IDS Life Series Fund
     Equity Portfolio                                      .70%               --               .03             .73%1
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Equity Income Portfolio                               .70%               --               .10             .80%2
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Government Securities Portfolio                       .70%               --               .10             .80%2
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Income Portfolio                                      .70%               --               .05             .75%1
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     International Equity Portfolio                        .95%               --               .10             1.05%1
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Managed Portfolio                                     .70%               --               .04             .74%1
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Money Market Portfolio                                .50%               --               .10             .60%1
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
AXPSM Variable Portfolio -
     Blue Chip Advantage Fund                              .56%               .13              .26             .95%3
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Bond Fund                                             .60%               .13              .08             .81%4
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Capital Resource Fund                                 .60%               .13              .06             .79%4
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Cash Management Fund                                  .51%               .13              .05             .69%4
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Diversified Equity Income Fund                        .56%               .13              .26             .95%4
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Emerging Markets Fund                                 1.27%              .13              .35             1.75%3
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Extra Income Fund                                     .62%               .13              .08             .83%4
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Federal Income Fund                                   .61%               .13              .14             .88%3
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Global Bond Fund                                      .84%               .13              .12             1.09%4
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Growth Fund                                           .63%               .13              .19             .95%3
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     International Fund                                    .83%               .13              .11             1.07%4
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Managed Fund                                          .59%               .13              .04             .76%4
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     New Dimensions Fund                                   .61%               .13              .07             .81%4
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     S&P 500 Index Fund                                    .37%               .13              --              .50%3
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Small Cap Advantage Fund                              .79%               .13              .31             1.23%3
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Strategy Aggressive Fund                              .60%               .13              .07             .80%4
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
AIM V.I.
     Capital Appreciation Fund                             .62%               --               .11             .73%5
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Capital Development Fund                                --%              --               1.23            1.23%5, 6
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Growth and Income Fund                                .61%               --               .16             .77%5
---------------------------------------------------------- ------------------ ---------------- --------------- -------------

<PAGE>

---------------------------------------------------------- ------------------ ---------------- --------------- -------------
American Century VP
     International                                         1.34%              --               --              1.34%7
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Value                                                 1.00%              --               --              1.00%7
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
Calvert CVS
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Social Balanced Portfolio                             .70%               --               .16             .86%8
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
Fidelity VIP
     III Growth & Income Portfolio (Service Class)         .48%               .10              .12             .70%9
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     III Mid Cap Portfolio (Service Class)                 .57%               .10              .40             1.07%10
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Overseas Portfolio (Service Class)                    .73%               .10              .18             1.01%9
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
FT VIPT
     Franklin Real Estate Fund - Class 2                   .56%               .25              .02             .83%11, 12
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Franklin Value Securities Fund - Class 2              .60%               .25              .21             1.06%11
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Templeton International Securities Fund - Class 2     .69%               .25              .19             1.13%11, 13
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Templeton International Smaller Companies Fund -      .85%               .25              .26             1.36%11
     Class 2
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
Goldman Sachs VIT
     CORESM Small Cap Equity Fund                          .75%               --               .25             1.00%14
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     CORESM U.S. Equity Fund                               .70%               --               .20             .90%14
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Mid Cap Value Fund                                    .80%               --               .25             1.05%14
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
Janus Aspen Series
     Aggressive Growth Portfolio: Service Shares           .65%               .25              .02             .92%15
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Global Technologies Portfolio: Service Shares         .65%               .25              .13             1.03%15
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     International Growth Portfolio: Service Shares        .65%               .25              .11             1.01%15
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
Lazard Retirement Series
     International Equity Portfolio                        .75%               .25              .25             1.25%16
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
MFS(R)  VIT
     Growth Series - Service Class                         .75%               .20              .16             1.11%17,
                                                                                                               18, 19
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     New Discovery Series - Service Class                  .90%               .20              .17             1.27%17,
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
Putnam Variable Trust
     Putnam VT High Yield Fund - Class IB Shares           .65%               .15              .07             .87%5
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Putnam VT International New Opportunities Fund -      1.08%              .15              .33             1.56%5
     Class IB Shares
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Putnam VT New Opportunities Fund - Class 1A Shares    .54%               --               .05             .59%5
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Putnam VT Vista Fund - Class IB Shares                .65%               .15              .10             .90%5
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
Royce
     Micro-Cap Portfolio                                   1.25%              --               .10             1.35%20
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
Third Avenue
     Value Portfolio                                       .90%               --               .40             1.30%21
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
Wanger
     International Small Cap                               1.25%              --               .24             1.49%22
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     U.S. Small Cap                                        .95%               --               .07             1.02%22
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
Warburg Pincus Trust
     Emerging Growth Portfolio                             --%                --               1.40            1.40%23
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
     Small Company Growth Portfolio                        .90%               --               .24             1.14%5
---------------------------------------------------------- ------------------ ---------------- --------------- -------------
</TABLE>

1Actual operating expenses for the fiscal year ending April 30, 1999.
2IDS Life has agreed to a voluntary  limit of 0.1%, on an annual  basis,  of the
average  daily net assets of each of the IDS Life  series Fund  Portfolio's  for
other  expenses  like  taxes  and  brokerage  commissions  and  for  nonadvisory
expenses.  If the 0.1%  limitation  had not been in place,  these other expenses
would  have  been  0.17%  for  IDS  Life  Series  Fund -  Government  Securities
Portfolio. IDS Life Series Fund - Equity Income Portfolio is new. IDS Life plans
to limit these  expenses to 0.1%.  IDS Life  reserves  the right to  discontinue
limiting  these other  expenses at 0.1%.  However,  its present  intention is to
continue the limit until the time that actual  expenses are less than the limit.
3Based on  estimated  expenses  after fee waivers and  expenses  reimbursements.
Without fee waivers and expense reimbursements "Other Expenses and "Total" would
be 0.39% and 1.08% for AXP  Variable  Portfolio  - Blue Chip  Advantage  and AXP
Variable  Portfolio  Diversified  Equity Income  Funds,  0.26% and 1.00% for AXP
Variable  Portfolio  - Federal  Income  Fund,  0.32% and 1.08% for AXP  Variable
Portfolio - Growth Fund and 0.43% and 1.35% for AXP  Variable  Portfolio - Small
Cap Advantage Fund.
4The fund's  expense  figures are based on actual  expenses  for the fiscal year
ended Aug. 31, 1999 restated to include a Rule 12b-1  distribution  fee of .125%
that went into effect Sept. 21, 1999.
5Figures in "Management  Fees," "Other Expenses" and "Total" are based on actual
expenses for the fiscal year ended Dec. 31, 1999.
6Had there been no fee  waivers or expense  reimbursement,  expenses  would have
been: 0.75%, 0.00%, 2.67% and 3.42%.
7The Fund has a stepped fee schedule.  As a result,  the fund's  management  fee
rate generally decreases as fund assets increase.
8Net fund operating  expenses after  reductions for fees paid  indirectly  again
restated  to  reflect an  indirect  for Social  Balanced  would be 0.89%.  Total
expenses have been restated to reflect expenses expected to be incurred in 2000.
9A portion  of the  brokerage  commissions  that  certain  funds pay was used to
reduce fund  expenses.  In addition,  through  arrangements  with certain funds'
custodian, credits realized as a result of uninvested cash balances were used to
reduce a portion of each  applicable  funds'  expenses.  With these  reductions,
"Other  Expenses," and "Total  Expenses"  presented in the table would have been
0.11% and 0.69% for Growth & Income  Portfolio  and 0.15% and 0.98% for Overseas
Portfolio.

<PAGE>

10FMR agreed to reimburse a portion of Mid Cap  Portfolio's  expenses during the
period. Without this reimbursement, the Portfolio's management fee, distribution
& service fee (12b-1),  other expenses and total expenses would have been 0.57%,
0.10% 2.74% and 3.41%,  respectively.
11The  fund's Class 2  distribution  plan or Rule 12b-1 plan is described in the
fund's prospectus.
12Previously  Franklin Real Estate Securities Fund. The fund  administration fee
is paid  indirectly  through the management fee. The fund's Class 2 distribution
plan or "Rule 12b-1 Plan" is described in the fund's prospectus.
13On Feb.  8,  2000,  shareholders  approved a merger  and  reorganization  that
combined the fund with the Templeton International Equity Fund, effective May 1,
2000. The shareholders of that fund approved new management fees, which apply to
the combined fund effective May 1, 2000. The table shows restated total expenses
based on the new fees and the assets of the funds as of Dec. 31,  1999,  and not
the assets of the combined fund.  However,  if the table  reflected both the new
fees and the combined  assets,  the fund's  expenses  after May 1, 2000 would be
estimated as: Management Fees 0.65%, 12b-1 Fees 0.25%, Other Expenses 0.20%, and
Total 1.10%.
14The fund's expenses are based on estimated  expenses for the fiscal year ended
Dec. 31, 2000. Goldman Sachs Asset Management and Goldman Sachs Asset Management
International,  the investment  advisers,  have voluntarily  agreed to reduce or
limit  certain other  expenses  (excluding  management  fees,  taxes,  interest,
brokerage fees, litigation, indemnification and other extraordinary expenses) to
the extent such  expenses  exceed the  percentage  stated in the above table (as
calculated  per  annum) of each  fund's  respective  average  daily net  assets.
Without the limitations  described  above,  Other Expenses and Total would be as
follows: 0.75% and 1.50% for CORE Small Cap Equity Fund, and 0.42% and 1.22% for
Mid Cap Value Fund  (formerly,  the Mid Cap Equity Fund) and 0.20% and 0.90% for
the CORESM U.S. Equity Fund, CORESM, is a service mark of Goldman Sachs and Co.
15Expenses are based on estimated  expenses that the new Service Shares class of
each  portfolio  expects to incur in its initial  fiscal year.  All expenses are
shown without the effect of expense offset arrangements.
16Effective May 1, 1999, the investment  adviser agreed to waive its fees and/or
reimburse the Funds through Dec. 31, 2000 to the extent that total Fund expenses
exceed 1.25% for Equity and 1.25% for International Equity of the Funds' average
daily net assets. Absent fee waivers and/or  reimbursements,  Other Expenses and
Total  Expenses  for the year ended  Dec.  31,  1999 would have been  11.94% and
12.94% for International Equity.
17Each series has adopted a  distribution  plan under Rule 12b-1 that permits it
to pay marketing and other fees to support the sales and distribution of service
class shares (these fees are referred to as distribution fees).
18Each  series has an expense  offset  arrangement  which  reduces  the  series'
custodian  fee based upon the amount of cash  maintained  by the series with its
custodian and dividend disbursing agent. The series may enter into other similar
arrangements  and  directed  brokerage  arrangements,  which would also have the
effect of  reducing  the series'  expenses.  "Other  Expenses"  do not take into
account  these  expense  reductions,  and are  therefore  higher than the actual
expenses of the series.  Had these fee reductions been taken into account,  "Net
Expenses" would be lower, and for service class shares would be estimated to be:
1.10% for Growth Series and 1.25% for New Discovery Series.
19MFS has contractually agreed,  subject to reimbursement,  to bear expenses for
the series'  expenses such that "Other  Expenses" (after taking into account the
expense  offset  arrangement  described  above),  do not exceed 0.15%  annually.
Without this agreement,  "Other Expenses" and Total would be 0.71% and 1.66% for
Growth Series and 1.59% and 2.69% for New Discovery  Series.  These  contractual
fee arrangements  will continue until at least May 1, 2001,  unless changed with
the consent of the board of trustees which oversees the series.
20Royce has contractually agreed to waive its fees and reimburse expenses to the
extent necessary to maintain the Funds Net Annual Operating  Expense ratio at or
below 1.35%  through Dec. 31, 1999 and 1.99%  through Dec. 31, 2008.  Absent fee
waivers "Other Expenses" and "Total Expenses" would be 0.99% and 2.24% for Royce
Micro-Cap Portfolio.
21These expenses reflect  reimbursements by the Adviser.  The Adviser reimbursed
the Fund  for all  expenses  incurred  by the  Fund in  excess  of 1.30% of Fund
assets.  The fund will repay the Adviser the amount of its  reimbursement for up
to three years  following  the  reimbursement  to the extent Fund  expenses drop
below 1.30%.  The Adviser  expects to continue to  reimburse  the Fund for these
expenses  for  the  foreseeable  future.  Either  the  Fund or the  Adviser  can
terminate this arrangement at any time. Without this  reimbursement,  the Fund's
"Other Expenses" and "Total" would have been 2.05% and 2.95%. Other expenses are
based on estimated amounts for the current fiscal year.
22Actual operating expenses of funds at Dec. 31, 1999.
23Expense ratios are shown after fee waivers and expenses  reimbursements by the
investment   adviser.   The  total   expense   ratios  before  the  waivers  and
reimbursements  would have been  11.16% for  Emerging  Growth  Portfolio  of the
Warburg Pincus Trust.

IDS Life of New York has also entered into certain  agreements under which it is
compensated by the funds' advisors and/or  distributors  for the  administrative
services provided to these funds.

                  (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, 2 and 3

                  See Item 13(a)(1).

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

                  Policy 1

                  (1)      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.

                  Policy 3

                    o    Premium expense charge: 3.5% of each premium payment.

                    o    Cost of  insurance  charge  for the  sex,  age and rate
                         classification for the assumed insured.

                    o    Policy fee: $5 per month.

                  Expenses  paid  by the  fund  and  charges  made  against  the
                  subaccounts.

<PAGE>

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

                  Not applicable.

         (e)      Furnish a brief  description of any loads,  fees,  expenses or
                  charges  not  covered  in  Item  13(a)  which  may be  paid by
                  security   holders  in  connection   with  the  trust  or  its
                  securities.

                  Policy 1

                  IDS Life 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.

                  Policy 3

                  Mortality and expense risk charge

                  This charge  applies  only to the  subaccounts  and not to the
                  fixed account. It is equal, on an annual basis, to 0.9% of the
                  average daily net asset value of the subaccounts for the first
                  10 policy  years and  0.45%  thereafter.  IDS Life of New York
                  reserves the right to charge up to 0.9% for all policy  years.
                  Computed  daily,  the charge  compensates IDS Life of New York
                  for:

<PAGE>

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

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

                  Any profit from the mortality and expense risk charge would be
                  available  to IDS Life 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 premium  expense  charge and surrender  charges  discussed
                  earlier. IDS Life of New York will make up any further deficit
                  from its general assets.

          (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(d)  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.  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.

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.

         Policies 1, 2 and 3

         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.      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.

<PAGE>
         Policies 1, 2 and 3

         The Owner determines in the application  what portions,  if any, of the
         premiums are to be allocated to each of the Subaccounts of the Variable
         Account,  the Fixed Account or both. Until the date that an application
         is  approved  by  IDS  Life  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.

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

         Policies 1, 2 and 3

         The Owner determines in the application  what portions,  if any, of the
         premiums are to be allocated to each of the Subaccounts of the Variable
         Account,  the Fixed Account or both. Until the date that an application
         is  approved  by  IDS  Life  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.

                  Policies 1, 2 and 3

                  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.

<PAGE>
                  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

                  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.

                  Policy 3

                  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.

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

                  A totally surrendered Policy will be canceled.

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

                  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.

<PAGE>
                  Policy 3

                  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, the account charged and the basis of determining the
                  amount of each charge.

                  Not applicable.

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

         IDS Life 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.
<PAGE>

         (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.

                  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.

<PAGE>
                  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.

                  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 notbeen 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.

<PAGE>
                  Policy 3

                  Policy loans

                  The  owner  may  borrow  against  the  policy  by  written  or
                  telephone request.  IDS Life of New York will process the loan
                  request at the end of the  valuation  period  during  which it
                  receives  the  request.  Loans by  telephone  are  limited  to
                  $50,000.

                  Interest  rate:  The interest  rate for policy loans is 6% per
                  year.  After the 10th anniversary IDS Life of New York expects
                  to  reduce  the loan  interest  to 4% per  year.  Interest  is
                  charged daily and due at the end of the policy year.

                  Minimum loan:  $200

                  Maximum loan:  90% of the policy value minus surrender
                                 charges.

                  IDS Life of New York will compute the maximum loan value as of
                  the end of the  valuation  period during which it receives the
                  loan request.  The amount available at any time for a new loan
                  is the maximum loan value less any existing indebtedness. When
                  IDS  Life  of New  York  computes  the  amount  available,  it
                  reserves the right to deduct from the loan value  interest for
                  the  period  until the next  policy  anniversary  and  monthly
                  deductions   that  it  will  take   until   the  next   policy
                  anniversary.

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

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

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

                  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 (IDS Life
                         of New York has not collected good payment);

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

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

                  IDS Life of New York may  delay  the  payment  of any loans or
                  surrenders  from the fixed  account up to six months  from the
                  date  it  receives  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 3% for the period of postponement.

<PAGE>

                    (c)  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.  The following items should be
                         covered:

                    (1)  The name of each  person who makes such  agreements  or
                         arrangements with security holders.
                    (2)  The rate of interest payable on such loans.
                    (3)  The period for which loans may be made.
                    (4)  Costs or charges for default in repayment at maturity.
                    (5)  Other   material   provisions   of  the   agreement  or
                         arrangement.

                  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.

                  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

                  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.  (See Repayments
                  Section under 21(a) 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.

<PAGE>
                  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.

                  Policy 3

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

                  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 the loan,
                  it will  reduce the death  benefit and cash  surrender  value.
                  Even if the owner does repay it, the loan can have a permanent
                  effect on death  benefits  and policy  values,  because  money
                  borrowed  against  the  subaccounts  will  not  share  in  the
                  investment results of the relevant fund(s).

                  A loan may terminate the no lapse  guarantee.  IDS Life of New
                  York  deducts the loan amount  from the total  premiums  paid,
                  which may reduce the total  below the level  required  to keep
                  the NLG in effect.

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

                  To be filed by amendment.

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.

<PAGE>

         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.

                  Policies 1 and 2

                  To be filed by amendment.

                  Policy 3

                  Not applicable.

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

                    (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 fiscal
                         year  covered  by  the   financial   statements   filed
                         herewith.

                  Policies 1, 2 and 3

                  IDS Life of New York has entered into certain  agreements with
                  which it is compensated by the advisers and/or distributors of
                  various funds for the administrative  services it provides for
                  these funds.

<PAGE>

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.

                  Timothy V. Bechtold

                  Director  since  April  1999;   president   since  1998,  Risk
                  Management Products since December 1999; vice president,  Risk
                  Management  Products,  IDS Life Insurance Company from January
                  1995 to  December  1999;  vice  president,  Insurance  Product
                  Development,  IDS  Life  Insurance  Company  from  May 1989 to
                  December 1994.

                  Maureen A. Buckley

                  Director since April 1999;  vice  president,  chief  operating
                  officer and consumer  affairs officer and claims officer since
                  1998;  chief operating  officer and consumer  affairs officer,
                  American Centurion Life Assurance  Company,  since March 1995;
                  supervisor,  IDS Life of New York from September 1989 to March
                  1995.

                  Rodney P. Burwell

                  Director  since  April  1999;  chairman,   Xerxes  Corporation
                  (manufacturing), since 1969.

                  John Cattau

                  Director since April 1999;  vice president,  American  Express
                  Financial  Direct,  since  November  1997;  manager,  American
                  express Financial Direct from June 1992 to November 1997.

<PAGE>
                  Robert R. Grew

                  Lawyer and Partner, Carter, Ledyard & Milburn, NYC, since
                  1957.

                  Jean B. Keffeler

                  Director since April 1999; business and management  consultant
                  since 1991.

                  Richard W. Kling

                  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.;  and
                  chairman of the board of managers  and  president  of IDS Life
                  Variable Annuity Funds A and B.

                  Thomas R. Mcburney

                  Director  since April  1999;  president,  McBurney  Management
                  Associates, since 1990.

                  Edward J. Muhl

                  Director since April 1999; vice chairman,  Peterson Consulting
                  LLP, since January 1997; superintendent of insurance, New York
                  State  from  January  1995  to  December  1996;   senior  vice
                  president,  Reliance  Insurance  Group from  November  1991 to
                  January 1995.

                  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.

                  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 other than directors

                  Darrell C. Beckstrom

                  Underwriting  officer  since  1994;   underwriting   technical
                  manger,  IDS Life, since 1990; senior  underwriter,  IDS Life,
                  from 1987 to 1992.

<PAGE>
                  Jeffrey W. Sullivan, M.D.

                  Medical director since 1998.

                  Lorraine R. Hart

                  Vice  President-Investments  since December  1999;  investment
                  officer   since  March   1992;   vice   president,   Insurance
                  Investments, IDS Life, since October 1989.

                  Eric L. Marhoun

                  General  counsel and secretary  since 1998;  group counsel and
                  vice president,  AEFA, since 1997;  counsel AEFA, from 1996 to
                  1997; associate counsel,  AEFA, from 1995 to 1996;  associate,
                  Meagher & Gear, from 1991 to 1995.

                  Jeffrey S. Horton

                  Vice  president  and  treasurer   since  December  1999;  vice
                  president,  treasurer and assistant secretary, IDS Life, since
                  December 1997; vice president and corporate  treasurer,  AEFC,
                  since   December   1997;    controller,    American    Express
                  Technologies-Financial  Services,  AEFC,  from  July  1997  to
                  December 1997;  controller,  Risk Management  Products,  AEFC,
                  from May 1994 to July 1997;  director of finance and analysis,
                  Corporate Treasury, AEFC from June 1990 to May 1994.

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:

<PAGE>

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

                  To be filed by amendment.

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

                  To be filed by amendment.

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

                  To be filed by amendment.

Compensation of Directors

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

         (a)      the aggregate direct remuneration to directors:

                  To be filed by amendment.

         (b)      indirectly or through subsidiaries to directors:

                  To be filed by amendment.

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.

<PAGE>

Compensation to Other Persons

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

         Not applicable - see Item 31.

                                       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  Policies 1 and 2 and intends to
         sell Policy 3 in New York only.

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.

<PAGE>

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.

                  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

                  IDS Life of New York pays its  representatives a commission of
                  up to 50% of the initial target premium  (annualized) when the
                  policy  is sold,  plus 2% of all  premiums  in  excess  of the
                  target premium.  IDS Life of New York also pays  approximately
                  27% of the total representative's commission to the field vice
                  presidents   and  district   sales  managers  of  the  selling
                  representative.

                  Policy 3

                  IDS Life of New York pays its  representatives a commission of
                  up  to  47.5%  of  the   initial   minimum   monthly   premium
                  (annualized)  when the policy is sold, plus 3% of all premiums
                  in excess of 12 times the minimum monthly premium. IDS Life of
                  New  York  pays  additional  commissions  if  an  increase  in
                  coverage occurs.  IDS Life of New York also pays approximately
                  27% of the total representative's commission to the field vice
                  presidents   and  district   sales  managers  of  the  selling
                  representative.

<PAGE>

Information Concerning Principal Underwriter

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

                  American Express Financial Advisors, Inc.
                  200 AXP Financial Center
                  Minneapolis, MN  55474

         (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.

                  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 600 supervisory offices and 3,800 branch offices and
                  more than 9,700 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.

<PAGE>

                  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.

                  Policies 1 and 2

                  To be filed by amendment.

                  Policy 3

                  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
<PAGE>
                  subaccount   will  be   reconverted   into  a  cash  value  by
                  multiplying  the  accumulation  unit  value by the  number  of
                  accumulation  units  necessary  to  equal  the  amount  to  be
                  transferred.  The amount  transferred  will then be  converted
                  into accumulation units of the second subaccount.

                  The investment  experience of a subaccount  reflects increases
                  or  decreases  in the net asset value of the  underlying  fund
                  shares or in the  value of units of the Trust and any  charges
                  against the assets in each  subaccount.  Policy values for the
                  subaccounts  are  determined  by  multiplying  the  number  of
                  accumulation   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.

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

<PAGE>

         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
                    o    any transfers to the subaccount (from the fixed account
                         or  other   subaccounts,   including   loan   repayment
                         transfers) during the period; minus
                    o    any  transfers  from  the  subaccount   including  loan
                         transfers during the current valuation period; minus
                    o    any  partial  surrenders  and  partial  surrender  fees
                         allocated to the subaccount during the period; minus
                    o    any portion of the monthly  deduction  allocated to the
                         subaccount during the period.

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

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

         Accumulation  units are the true  measure of  investment  value in each
         subaccount.  For subaccounts investing in the fund, 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
                    o    any credit or minus any charge  for  reserves  to cover
                         any tax liability in the preceding valuation period.

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

         Factors that affect subaccount accumulation units:

         Accumulation units may change in two ways; in number and in value. Here
         are the factors that influence those changes:

         The number of accumulation units the owner owns may fluctuate due to:

<PAGE>

                    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.

                  Policy 3

                  Policy value

                  The  value of the  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 equals:

                    o    the portion of the initial net premium allocated to the
                         fixed account; plus
                    o    interest accrued before the policy date; minus
                    o    the  portion  of the  monthly  deduction  for the first
                         policy month 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  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 funds in which that  subaccount
                  invests  and on  other  factors  detailed  below.  There is no
                  guaranteed  minimum  subaccount  value.  The  owner  bears the
                  entire investment risk.

                  Calculation of subaccount  value: The value of each subaccount
                  on the policy date equals:

<PAGE>

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

                  The value on each subaccount on each valuation date equals:

                    o    the value of the subaccount on the preceding  valuation
                         date,  multiplied by the net investment  factor for the
                         current valuation period (explained below); plus
                    o    net premiums  received and allocated to the  subaccount
                         during the current valuation period; plus
                    o    any transfers to the subaccount (from the fixed account
                         or  other   subaccounts,   including   loan   repayment
                         transfers) during the period; minus
                    o    any  transfers  from  the  subaccount   including  loan
                         transfers during the current valuation period; minus
                    o    any  partial  surrenders  and  partial  surrender  fees
                         allocated to the subaccount during the period; minus
                    o    any portion of the monthly  deduction  allocated to the
                         subaccount during the period.

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

                  Accumulation  units:  IDS Life of New York converts the policy
                  value allocated to each subaccount  into  accumulation  units.
                  Each time the owner  directs a  premium  payment  or  transfer
                  policy value into one of the subaccounts, IDS Life of New York
                  credits a certain number of  accumulation  units to the policy
                  for that subaccount.  Conversely,  each time the owner takes a
                  partial  surrender or transfer value out of a subaccount,  IDS
                  Life of New York  subtracts a certain  number of  accumulation
                  units.

                  Accumulation units are the true measure of investment value in
                  each subaccount.  For subaccounts investing in the funds, they
                  are  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  funds,  and on certain charges.
                  Here is how unit values are calculated:

                  Number  of  units:  To  calculate  the  number  of units for a
                  particular subaccount, the investment (net premium or transfer
                  amount) is divided by the current accumulation unit value.

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

                  Net investment factor: The net investment factor is determined
                  at the end of each valuation period. This factor equals

                                          (a divided by b) - c,
                  where:

<PAGE>

                  (a) equals:

                    o    net asset value per share of the fund; plus
                    o    per-share  amount  of  any  dividend  or  capital  gain
                         distribution   made  by  the   relevant   fund  to  the
                         subaccount; plus
                    o    any credit or minus any charge  for  reserves  to cover
                         any  tax  liability   resulting   from  the  investment
                         operations of the subaccount.

                  (b) equals:

                    o    net asset value per share of the fund at the end of the
                         preceding valuation period; plus
                    o    any credit or minus any charge  for  reserves  to cover
                         any tax liability in the preceding valuation period.

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

                  Factors   that   affect   subaccount    accumulation    units:
                  Accumulation  units of each subaccount may change in two ways;
                  in number  and in value.  The  factors  that  influence  those
                  changes are:

                  The number of accumulation units owned may fluctuate due to:

                    o    additional premiums allocated to the subaccount;
                    o    transfers into or out of the subaccount;
                    o    partial surrenders and partial surrender fees;
                    o    surrender charges; and/or
                    o    pro rata portions of the monthly deductions

                  Accumulation unit values will fluctuate due to:

                    o    changes in underlying fund's net asset value;
                    o    dividends distributed to the subaccount;
                    o    capital gains or losses of underlying fund;
                    o    fund 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 and 2

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

                  Policy 3

                  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.

<PAGE>
                  Policies 1, 2 and 3

                  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:

         (a)      by whose action redemption rights were suspended.

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

         (c)      reason for suspension.

         (d)      period during which suspension was in effect.

         Not applicable.

Redemption Valuation of Securities of the Trust

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

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

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

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

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

                  (3)      Whether price is as of the day of sale or as of any
                           other time.

                           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.

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

                  Not applicable.

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

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

         Policies 1, 2 and 3

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

                                       V.

                 INFORMATION CONCERNING THE TRUSTEE OR CUSTODIAN

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

         (a)      Name and principal business address:

                  Not applicable as IDS Life 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.

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

                  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.

                  Policy 3

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

         (c)      The types of risks insured and excluded.

                  Under the Policies the Company  assumes the risk that insureds
                  covered by the  Policies may die before  anticipated  and that
                  the charge for this mortality risk may prove insufficient. The
                  Company  assumes an expense risk that  deductions for expenses
                  may not be adequate.  Under 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 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.

                  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:

<PAGE>
                           (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.

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

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

                  A death  benefit  guarantee  charge is included in the monthly
                  deduction  in  the  first  five  policy  years  or  until  the
                  insured's attained age 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.

                  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.

                  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.

                  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.

<PAGE>
                  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.

                  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 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.

                  Keeping the policy in force

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

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

                  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.

<PAGE>
                  Death benefit guarantee to age 100

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

                           the sum of premiums paid 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 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.

<PAGE>
                  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.

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

                  Policy 3

                  Payment of premiums:
                  In  applying  for the  policy,  the owner must decide how much
                  they  intend  to pay and how often  they  will make  payments.
                  During the first  several  policy years until the policy value
                  is sufficient to cover the surrender  charge,  IDS Life of New
                  York requires  that the owner pay premiums  sufficient to keep
                  the NLG in effect in order to keep the policy in force.

                  The owner may  schedule  payments  annually,  semiannually  or
                  quarterly.  (IDS Life of New York must approve  payment at any
                  other  interval).  IDS Life of New  York  shows  this  premium
                  schedule in the policy.

                  The  scheduled  premium  serves only as an  indication  of the
                  owner's  intent  as to the  frequency  and  amount  of  future
                  premium  payments.   The  owner  may  skip  scheduled  premium
                  payments at any time if the cash surrender value is sufficient
                  to pay the monthly  deduction or if  sufficient  premiums have
                  been paid to keep the no lapse guarantee in effect.

                  The  owner  may  also  change  the  amount  and  frequency  of
                  scheduled premium payments by written request. IDS Life 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 the  payments  will affect the policy
                  value, cash surrender value and length of time the policy will
                  remain in force,  as well as affect whether the NLG remains in
                  effect.

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

                  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.

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

                  IDS Life of New  York  converts  any  amount  that  the  owner
                  allocates  to a  subaccount  into  accumulation  units of that
                  subaccount.  Similarly, when the owner transfers value between
                  subaccounts,  IDS Life of New York converts accumulation units
                  in one  subaccount  into a cash  value,  which IDS Life of New
                  York  then  converts  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
                  person  whose  life the owner  proposes  to  insure  (owner or
                  someone else). The underwriting  department of IDS Life of New
                  York will review the application  and any medical  information
                  or other data  required  to  determine  whether  the  proposed
                  individual  is insurable  under its  underwriting  rules.  The
                  application may be declined if IDS Life of New York determines
                  the  individual is not insurable and IDS Life of New York will
                  return any premium paid.

                  Age  limit:  IDS Life of New York  generally  will not issue a
                  policy where the proposed insured is over the insurance age of
                  80. It may, however, do so at its sole discretion.

                  Keeping The Policy in Force

                  No lapse guarantee (NLG)

                  The NLG  provides  that your  policy  will remain in force for
                  five  policy  years,  even  if the  cash  surrender  value  is
                  insufficient to pay the monthly  deduction.  The NLG will stay
                  in effect as long as:

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

                  The minimum monthly premium is shown in the policy.

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

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

                  Grace period

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

<PAGE>
                  IDS Life of New York will mail a notice  to the  owner's  last
                  known  address,  requesting  payment of the premium  needed so
                  that it can make the next  three  monthly  deductions.  If IDS
                  Life of New York receives  this premium  before the end of the
                  61-day  grace  period,  it will use the  payment  to cover all
                  monthly deductions and any other charges then due. IDS Life of
                  New York will add any balance to the policy value and allocate
                  it in the same manner as other premium payments.

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

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

                  Policy 1

                  To be filed by amendment.

                  Policy 2

                  To be filed by amendment.

                  Policy 3

                  No policy is currently being sold.

         (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.

<PAGE>
                  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.

                  Policy 3

                  IDS Life of New York  deducts a premium  expense  charge  from
                  each premium  payment.  It credits the amount  remaining after
                  the deduction,  called the net premium,  to the account(s) the
                  owner has selected. The premium expense charge is 3.5% of each
                  premium payment. It partially compensates IDS Life of New York
                  for expenses of  distributing  the policy,  including  agents'
                  commissions,  advertising  and  printing of  prospectuses  and
                  sales literature. It also compensates IDS Life of New York for
                  paying  taxes  imposed  by  certain  states  and  governmental
                  subdivisions on premiums received by insurance companies.  All
                  policies in all states are charged  the same  premium  expense
                  charge even though state premium taxes vary.

                  No person other than IDS Life of New York receives any part of
                  the  premiums or the amounts  deducted for the  mortality  and
                  expense risk charge or other applicable  charges.  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.

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

                  Not applicable.

<PAGE>

                                      VII.

                              POLICY OF REGISTRANT

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

                    If shares of any Fund  Portfolio  and/or  units of the Trust
                    should not be  available  for  purchase  by the  appropriate
                    Subaccount  or if, in the judgment of IDS Life 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;

                  (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).

<PAGE>

         (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.

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.

<PAGE>
         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:

                    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.

<PAGE>
<TABLE>
<CAPTION>

Illustration                                                                    Policies purchased before May 1, 1993
----------------------------------------------------------------------------------------------------------------------
Initial specified amount                            Male age 35                            Current costs assumed
$100,000 Death benefit Option 1                     Nonsmoker                              annual premium $900
----------------------------------------------------------------------------------------------------------------------
            Premium        Death benefit (1)(2)        Policy value (1)(2) assuming     Cash surrender value (1)(2)
          accumulated   assuming hypothetical gross     hypothetical gross annual       assuming hypothetical gross
          with annual   annual investment return of        investment return of         annual investment return of
 End of     interest
 policy
  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.

<PAGE>
<TABLE>
<CAPTION>


                                                                           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 Option 1                     Nonsmoker                              annual premium $900
----------------------------------------------------------------------------------------------------------------------
            Premium         Death benefit (1)(2)       Policy value (1)(2) assuming     Cash surrender value (1)(2)
          accumulated    assuming hypothetical gross     hypothetical gross annual      assuming hypothetical gross
          with annual    annual investment return of       investment return of         annual investment return of
 End of     interest
 Policy
  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.

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

<PAGE>
<TABLE>
<CAPTION>


Illustration                                                      Policies purchased on or after November 20, 1997
-----------------------------------------------------------------------------------------------------------------------
Initial specified amount                            Male age 35                            Current costs assumed
$100,000 Death benefit Option 1                     Nonsmoker                              annual premium $900
-----------------------------------------------------------------------------------------------------------------------
            Premium        Death benefit (1)(2)        Policy value (1)(2) assuming     Cash surrender value (1)(2)
          accumulated   assuming hypothetical gross     hypothetical gross annual       assuming hypothetical gross
          with annual   annual investment return of        investment return of         annual investment return of
 End of    interest
 policy
  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.

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

<PAGE>
<TABLE>
<CAPTION>

Illustration
----------------------------------------------------------------------------------------------------------------------
Initial specified amount                            Male age 35                          Guaranteed costs assumed
$100,000 Death benefit Option 1                     Nonsmoker                              annual premium $900
----------------------------------------------------------------------------------------------------------------------
            Premium        Death benefit (1)(2)        Policy value (1)(2) assuming     Cash surrender value (1)(2)
          accumulated   assuming hypothetical gross     hypothetical gross annual       assuming hypothetical gross
          with annual   annual investment return of        investment return of         annual investment return of
 End of    interest
 policy
  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      3,445      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

   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      7,146     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.

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

<PAGE>

Policy 2

Policy illustrations

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

     o   the annual rate of return of the fund is 0%, 6% or 12%.

     o   the cost of insurance rates are current rates or guaranteed rates.

This type of 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,  we will furnish you with  comparable  tables  illustrating  death
benefits,  policy values and cash  surrender  values based on the actual ages of
the persons you propose to insure and on an initial specified amount and premium
payment  schedule.  In  addition,  after you have  purchased  a policy,  you may
request illustrations based on policy values at the time of request.

Understanding the illustrations:

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

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

Premiums:  assumes a $15,000 premium 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:  assumes that none have been made. (Since
we assume indebtedness is zero, the cash surrender value in all cases equals the
policy value minus the surrender charge.)

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

     o   Sales charge: 7.25% of all premiums paid.

     o   Premium tax charge: 1.0% of each premium payment.

     o   Federal tax charge: 1.25% of each premium payment.

     o   Cost of  insurance  charge for the sex, age and risk  classification
         for each insured.

     o   Policy fee: $30 per month ($30 per month guaranteed maximum).

     o   The expenses paid by the fund and charges made against the subaccounts
         as described below:

<PAGE>

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

     o   the daily  investment  management fee paid by the funds,  assumed to be
         equivalent to an annual rate of 0.70% of the fund's  aggregate  average
         daily  net  assets;   the   assumed   investment   management   fee  is
         approximately  equal to a simple average of the  investment  management
         fees of the funds  available  under the policy.  The actual charges you
         incur will depend on how you choose to allocate policy value.  See Fund
         expenses in the Loads,  fees and charges  section of the prospectus for
         additional information;

     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  paid  by  the  funds,  assumed  to  be
         equivalent  to an annual rate of 0.1% of each funds  aggregate  average
         daily net assets for direct expenses  incurred by the fund;  currently,
         this is the maximum direct  expenses the fund will incur after IDS Life
         limits the direct expenses of some funds.  The actual charges you incur
         will  depend  on how you  choose to  allocate  policy  value.  See Fund
         expenses in the Loads,  fees and charges section of this prospectus for
         additional information.

After  deduction of the expenses and charges  described  above,  the illustrated
gross annual investment rates of return correspond to the following  approximate
net annual rates of return:

                             Net annual rate of             Net annual rate of
                             return for "Guaranteed return  for "Current
Gross annual investment      costs assumed"                 costs assumed"
rate                         illustration                   illustration
of return

 0%                          -1.69%                     -1.69%

 6                            4.21                       4.21

12                           10.11                      10.11

Taxes:  Results  shown in the tables  reflect the fact that IDS Life of New York
does not currently  charge the  subaccounts  for federal  income tax. If we take
such a charge in the future,  the portfolios will have to earn more than they do
now in order to produce the death benefits and policy values illustrated.

<PAGE>
<TABLE>
<CAPTION>

Illustration
-------------------------------------- -------------------------------------------------------- --------------------------------
Initial  specified amount $1,000,000         Male - Insurance age 55 - Nonsmoker                 Current costs  assumed
Death  benefit  Option 1                    Female -  Insurance  age 55 - Nonsmoker              annual premium $15,000
-------------------------------------- -------------------------------------------------------- --------------------------------
          Premium       Death benefit                         Policy Value                      Cash surrender value
          accumulated   assuming hypothetical gross           Assuming hypothetical gross       assuming hypothetical gross
End of    with annual   annual investment return of           annual investment return of       annual investment return of
policy    interest
year      at 5%             0%           6%          12%         0%          6%         12%         0%         6%          12%
--------- ------------- ------------ ----------- ------------ ---------- ----------- ---------- ----------- ---------- --------
<S>  <C>           <C>         <C>          <C>          <C>        <C>         <C>        <C>        <C>         <C>
   1  $   15,750    $1,000,000   $1,000,000  $1,000,000   $  12,873  $   13,658  $  14,444  $    8,873  $   9,658  $   10,444
   2      32,288     1,000,000    1,000,000   1,000,000       25,530     27,894      30,351     21,530      23,894     26,351
   3      49,652     1,000,000    1,000,000   1,000,000       37,861     42,613      47,748     33,861      38,613     43,748
   4      67,884     1,000,000    1,000,000   1,000,000       49,762     57,726      66,673     45,762      53,726     62,673
   5      87,029     1,000,000    1,000,000   1,000,000       61,357     73,370      87,406     57,357      69,370     83,406

   6     107,130     1,000,000    1,000,000   1,000,000       72,345     89,348     109,911     68,835      85,748    106,311
   7     128,237     1,000,000    1,000,000   1,000,000       83,118    105,796     134,496     79,918     102,596    131,296
   8     150,398     1,000,000    1,000,000   1,000,000       93,206    122,528     161,172     90,406     119,728    158,372
   9     173,668     1,000,000    1,000,000   1,000,000      102,715    139,571     190,184    100,315     137,171    187,784
   10    198,102     1,000,000    1,000,000   1,000,000      111,665    156,958     221,800    109,665     154,958    219,800

   11    223,757     1,000,000    1,000,000   1,000,000      119,966    174,619     256,230    118,366     173,019    254,630
   12    250,695     1,000,000    1,000,000   1,000,000      127,742    192,687     293,902    126,542     191,487    292,702
   13    278,979     1,000,000    1,000,000   1,000,000      134,904    211,101     335,108    134,104     210,301    334,308
   14    308,678     1,000,000    1,000,000   1,000,000      141,366    229,807     380,196    140,966     229,407    379,796
   15    339,682     1,000,000    1,000,000   1,000,000      147,249    248,938     429,722    147,249     248,938    429,722

   20    520,789     1,000,000    1,000,000   1,000,000      167,997    352,728     766,596    167,997     352,728    766,596
   25    751,502     1,000,000    1,000,000   1,390,706      157,050    461,226   1,324,482    157,050     461,226  1,324,482
   30  1,046,412     1,000,000    1,000,000   2,327,541       53,339    547,683   2,216,705     53,339     547,683  2,216,705
   35  1,422,545             0    1,000,000   3,792,346            0    561,352   3,611,758          0     561,352  3,611,758
   40  1,902,596             0    1,000,000   6,052,646            0    425,780   5,764,425          0     425,780  5,764,425
   45  2,515,277             0            0   9,254,030            0          0   9,162,406          0           0  9,162,406

</TABLE>

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

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

The above  hypothetical  investment results are illustrative only and you should
not consider them to be a representation of past or future  investment  results.
Actual  investment  results  may be more or less  than  those  shown.  The death
benefit,  policy value and cash  surrender  value would be different  from those
shown if returns  averaged 0%, 6% and 12% over a period of years, but fluctuated
above and below those averages for individual policy years. We can not represent
that  these  hypothetical  rates of return can be  achieved  for any one year or
sustained over any period of time.

<PAGE>
<TABLE>
<CAPTION>

Illustration
-------------------------------------- ------------------------------------------------------- ---------------------------------
Initial  specified  amount  $1,000,000     Male  -  Insurance  age  55 -  Nonsmoker            Guaranteed  costs  assumed
Death  benefit  Option 1                  Female - Insurance age 55 - Nonsmoker                annual premium $15,000
-------------------------------------- ------------------------------------------------------- ---------------------------------
          Premium     Death benefit                        Policy Value                        Cash surrender value
          accumulated assuming hypothetical gross          Assuming hypothetical gross         assuming hypothetical gross
End of    with        annual investment return of          annual investment return of         annual investment return of
policy    annual
          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   $   15,750  $1,000,000   $1,000,000  $1,000,000  $   12,873  $   13,658  $   14,444  $    8,873  $    9,658  $   10,444
   2       32,288   1,000,000    1,000,000   1,000,000      25,530      27,894      30,351      21,530      23,894      26,351
   3       49,652   1,000,000    1,000,000   1,000,000      37,861      42,613      47,748      33,861      38,613      43,748
   4       67,884   1,000,000    1,000,000   1,000,000      49,762      57,726      66,673      45,762      53,726      62,673
   5       87,029   1,000,000    1,000,000   1,000,000      61,357      73,370      87,406      57,357      69,370      83,406

   6      107,130   1,000,000    1,000,000   1,000,000      72,345      89,348     109,911      68,835      85,748     106,311
   7      128,237   1,000,000    1,000,000   1,000,000      83,118     105,796     134,496      79,918     102,596     131,296
   8      150,398   1,000,000    1,000,000   1,000,000      93,206     122,528     161,172      90,406     119,728     158,372
   9      173,668   1,000,000    1,000,000   1,000,000     102,715     139,571     190,184     100,315     137,171     187,784
   10     198,102   1,000,000    1,000,000   1,000,000     111,560     156,855     221,701     109,560     154,855     219,701

   11     223,757   1,000,000    1,000,000   1,000,000     119,550     174,206     255,834     117,950     172,606     254,234
   12     250,695   1,000,000    1,000,000   1,000,000     126,712     191,660     292,919     125,512     190,460     291,719
   13     278,979   1,000,000    1,000,000   1,000,000     132,862     209,056     333,162     132,062     208,256     332,362
   14     308,678   1,000,000    1,000,000   1,000,000     137,924     226,334     376,912     137,524     225,934     376,512
   15     339,682   1,000,000    1,000,000   1,000,000     141,819     243,440     424,586     141,819     243,440     424,586

   20     520,789   1,000,000    1,000,000   1,000,000     133,698     318,689     740,657     133,698     318,689     740,657
   25     751,502   1,000,000    1,000,000   1,332,763      28,958     338,168   1,269,298      28,958     338,168   1,269,298
   30   1,046,412   1,000,000    1,000,000   2,213,730           0     192,246   2,108,314           0     192,246   2,108,314
   35   1,422,545           0    1,000,000   3,556,762           0           0   3,387,393           0           0   3,387,393
   40   1,902,596           0    1,000,000   5,532,845           0           0   5,269,376           0           0   5,269,376
   45   2,515,277           0            0   8,165,971           0           0   8,085,120           0           0   8,085,120

</TABLE>

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

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

The above  hypothetical  investment results are illustrative only and you should
not consider them to be a representation of past or future  investment  results.
Actual  investment  results  may be more or less  than  those  shown.  The death
benefit,  policy value and cash  surrender  value would be different  from those
shown if returns  averaged 0%, 6% and 12% over a period of years, but fluctuated
above and below those averages for individual policy years. We can not represent
that  these  hypothetical  rates of return can be  achieved  for any one year or
sustained over any period of time.

<PAGE>
<TABLE>
<CAPTION>

Illustration
-------------------------------------- ------------------------------------------------------- --------------------------------
Initial  specified amount $1,000,000         Male - Insurance age 55 - Nonsmoker               Current costs  assumed
Death  benefit  Option 2                    Female -  Insurance  age 55 - Nonsmoker            annual premium $15,000
-------------------------------------- ------------------------------------------------------- --------------------------------
          Premium       Death benefit                       Policy value                       Cash surrender value
          accumulated   assuming hypothetical gross         Assuming hypothetical gross        assuming hypothetical gross
End of    with annual   annual investment return of         Annual investment return of        annual investment return of
policy    interest
year      at 5%             0%          6%         12%          0%          6%         12%        0%          6%          12%
--------- ------------- ----------- ----------- ----------- ----------- ----------- ---------- ---------- ------------ ----------
<S>  <C>           <C>         <C>         <C>         <C>         <C>         <C>        <C>        <C>         <C>
   1  $   15,750    $1,012,871  $1,013,656  $1,014,442  $   12,871  $   13,656  $  14,442  $   8,871  $    9,656   $   10,442
   2      32,288     1,025,525   1,027,888   1,030,345      25,525      27,888      30,345     21,525     23,888       26,345
   3      49,652     1,037,847   1,042,598   1,047,730      37,847      42,598      47,730     33,847     38,598       43,730
   4      67,884     1,049,725   1,057,682   1,066,621      49,725      57,682      66,621     45,725     53,682       62,621
   5      87,029     1,061,283   1,073,280   1,087,296      61,283      73,280      87,296     57,283     69,280       83,296

   6     107,130     1,072,292   1,089,168   1,109,685      72,292      89,168     109,685     68,692     85,568      106,085
   7     128,237     1,082,878   1,105,481   1,134,085      82,878     105,481     134,085     79,678    102,281      130,885
   8     150,398     1,092,812   1,121,993   1,160,449      92,812     121,993     160,449     90,012    119,193      157,649
   9     173,668     1,102,104   1,138,711   1,188,975     102,104     138,711     188,975     99,704    136,311      186,575
   10    198,102     1,110,766   1,155,644   1,219,882     110,766     155,644     219,882    108,766    153,644      217,882

   11    223,757     1,118,690   1,172,680   1,253,285     118,690     172,680     253,285    117,090    171,080      251,685
   12    250,695     1,126,006   1,189,945   1,289,563     126,006     189,945     289,563    124,806    188,745      288,363
   13    278,979     1,132,607   1,207,327   1,328,880     132,607     207,327     328,880    131,807    206,527      328,080
   14    308,678     1,138,386   1,224,708   1,371,418     138,386     224,708     371,418    137,986    224,308      371,018
   15    339,862     1,143,475   1,242,210   1,417,630     143,475     242,210     417,630    143,475    242,210      417,630

   20    520,789     1,158,144   1,330,920   1,717,417     158,144     330,920     717,417    158,144    330,920      717,417
   25    751,502     1,135,016   1,398,674   2,156,241     135,016     398,674   1,156,241    135,016    398,674    1,156,241
   30  1,046,412     1,012,373   1,366,625   2,735,967      12,373     366,625   1,735,967     12,373    366,625    1,735,967
   35  1,422,545             0   1,085,371   3,399,883           0      85,371   2,399,883          0     85,371    2,399,883
   40  1,902,596             0           0   4,166,038           0           0   3,166,038          0          0    3,166,038
   45  2,515,277             0           0   4,610,673           0           0   3,610,673          0          0    3,610,673

</TABLE>

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

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

The above  hypothetical  investment results are illustrative only and you should
not consider them to be a representation of past or future  investment  results.
Actual  investment  results  may be more or less  than  those  shown.  The death
benefit,  policy value and cash  surrender  value would be different  from those
shown if returns  averaged 0%, 6% and 12% over a period of years, but fluctuated
above and below those averages for individual policy years. We can not represent
that  these  hypothetical  rates of return can be  achieved  for any one year or
sustained over any period of time.

<PAGE>
<TABLE>
<CAPTION>

Illustration
-------------------------------------- ------------------------------------------------------- ---------------------------------
Initial  specified  amount  $1,000,000       Male  -  Insurance age  55 - Nonsmoker            Guaranteed  costs  assumed
Death  benefit  Option 2                    Female - Insurance age 55 - Nonsmoker              annual premium $15,000
-------------------------------------- ------------------------------------------------------- ---------------------------------
          Premium        Death benefit                      Policy value                       Cash surrender value
          accumulated    assuming hypothetical gross        assuming hypothetical gross        assuming hypothetical gross
End of    with annual    annual investment return of        annual investment return of        annual investment return of
policy    interest
year      at 5%              0%         6%         12%          0%         6%         12%          0%          6%         12%
--------- -------------- ----------- ---------- ----------- ----------- ---------- ----------- ----------- ----------- ----------
<S>  <C>           <C>          <C>        <C>          <C>         <C>        <C>         <C>        <C>         <C>
   1  $   15,750     $1,012,871  $1,013,656 $1,014,442    $ 12,871   $  13,656  $  14,442    $  8,871  $    9,656   $  10,442
   2      32,288      1,025,525   1,027,888  1,030,345      25,525      27,888     30,345      21,525      23,888      26,345
   3      49,652      1,037,847   1,042,598  1,047,730      37,847      42,598     47,730      33,847      38,598      43,730
   4      67,884      1,049,725   1,057,682  1,066,621      49,725      57,682     66,621      45,725      53,682      62,621
   5      87,029      1,061,283   1,073,280  1,087,296      61,283      73,280     87,296      57,283      69,280      83,296

   6     107,130      1,072,292   1,089,168  1,109,685      72,292      89,168    109,685      68,692      85,568     106,085
   7     128,237      1,082,878   1,105,481  1,134,085      82,878     105,481    134,085      79,678     102,281     130,885
   8     150,398      1,092,812   1,121,993  1,160,449      92,812     121,993    160,449      90,012     119,193     157,649
   9     173,668      1,102,104   1,138,711  1,188,975     102,104     138,711    188,975      99,704     136,311     186,575
   10    198,102      1,110,648   1,155,522  1,219,756     110,648     155,522    219,756     108,648     153,522     217,756

   11    223,757      1,118,218   1,172,186  1,252,769     118,218     172,186    252,769     116,618     170,586     251,169
   12    250,695      1,124,832   1,188,697  1,288,238     124,832     188,697    288,238     123,632     187,497     287,038
   13    278,979      1,130,268   1,204,803  1,326,162     130,268     204,803    326,162     129,468     204,003     325,362
   14    308,678      1,134,428   1,220,367  1,366,663     134,428     220,367    366,663     134,028     219,967     366,263
   15    339,862      1,137,214   1,235,241  1,409,875     137,214     235,241    409,875     137,214     235,241     409,875

   20    520,789      1,118,740   1,284,564  1,662,467     118,740     284,564    662,467     118,740     284,564     662,467
   25    751,502              0   1,227,701  1,937,570           0     227,701    937,570           0     227,701     937,570
   30  1,046,412              0           0  2,126,774           0           0  1,126,774           0           0   1,126,774
   35  1,422,545              0           0  1,994,219           0           0    994,219           0           0     994,219
   40  1,902,596              0           0  1,170,462           0           0    170,462           0           0     170,462
   45  2,515,277              0           0          0           0           0          0           0           0           0

</TABLE>

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

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

The above  hypothetical  investment results are illustrative only and you should
not consider them to be a representation of past or future  investment  results.
Actual  investment  results  may be more or less  than  those  shown.  The death
benefit,  policy value and cash  surrender  value would be different  from those
shown if returns  averaged 0%, 6% and 12% over a period of years, but fluctuated
above and below those averages for individual policy years. We can not represent
that  these  hypothetical  rates of return can be  achieved  for any one year or
sustained over any period of time.

<PAGE>

Policy 3

Policy Illustations

The following  tables  illustrate how policy values,  cash surrender  values and
death benefits may change with the investment experience of the subaccount.  The
tables show how these amounts  might vary,  for a  35-year-old  male  nonsmoker,
under Death Benefit Option 1, if:

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

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

Upon request,  we will furnish you 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: assumes uniform,  gross,  after-tax,  annual rates of 0%, 6% or
12% for the fund.  Results  would  differ  depending  on  allocations  among the
subaccounts,  if  returns  averaged  0%,  6% and 12% for the fund as a whole but
differed across portfolios.

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

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

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

Effect of expenses and charges

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

                    o    Premium expense charge: 3.5% of each premium payment.

                    o    Cost of  insurance  charge  for the  sex,  age and rate
                         classification for the assumed insured.

                    o    Policy fee: $5 per month.

The  expenses  paid by the fund and  charges  made  against the  subaccounts  as
described below:

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

<PAGE>

o    the  daily  investment  management  fee  paid by the  fund,  assumed  to be
     equivalent  to an  annual  rate of 0.73% of the  fund's  average  daily net
     assets; the assumed investment  management fee is approximately  equal to a
     simple average of the investment  management  fees,  based on assets of the
     subaccounts,  of the funds available  under the policy.  The actual charges
     you incur will depend on how you choose to allocate policy value.  See Fund
     expenses in the Loads,  Fees and  Charges  section of this  prospectus  for
     additional information;

o    the 12b-1 fee, assumed to be equivalent to an annual rate of 0.09% 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 for the first 10 policy
     years and 0.45%  thereafter,  we reserve the right to charge up to 0.9% for
     all policy years; and

o    a nonadvisory  expense charge assumed to be equivalent to an annual rate of
     0.17% of each fund's average daily net assets for direct expenses  incurred
     by the fund.  The actual charges you incur will depend on how you choose to
     allocate  policy value.  See Fund expenses in the Loads,  Fees, and Charges
     section of this prospectus for additional information.

After  deduction of the expenses and charges  described  above,  the illustrated
gross annual investment rates of return correspond to the following  approximate
net annual rates of return:
<TABLE>
<CAPTION>

                             Net annual rate of         Net annual rate of         Net annual rate of
Gross annual investment      return for "Guaranteed     return for "Current        return for "Current
rate                         costs assumed"             costs assumed"             costs assumed"
Of return                    illustration               illustration, years 1-10   illustration, years 11
                                                                                   and after
<S>                        <C>                        <C>                        <C>
 0%                          (1.87)%                    (1.87)%                    (1.43)%

 6                             4.02                       4.02                      4.48

12                             9.90                       9.90                     10.40

</TABLE>

Taxes:  Results  shown in the tables  reflect the fact that IDS Life of New York
does not currently  charge the  subaccounts  for federal  income tax. If we take
such a charge in the future,  the portfolios will have to earn more than they do
now in order to produce the death benefits and policy values illustrated.

<PAGE>
<TABLE>
<CAPTION>

Illustration
-------------------------------------------------------------------------------------------------------------------------------
Initial specified amount $100,000                             Male age 35                        Current costs assumed
Death benefit Option 1                                        nonsmoker                          Annual premium $900
-------------------------------------------------------------------------------------------------------------------------------
          Premium               Death benefit (1)(2)                Policy value (1)(2)            Cash surrender value (1)(2)
          accumulated           assuming hypothetical gross         assuming hypothetical gross    assuming hypothetical gross
End of    with annual           annual investment return of         annual investment return of    annual investment return of
policy     interest
year        at 5%           0%          6%           12%        0%         6%          12%        0%          6%        12%
-------------------------------------------------------------------------------------------------------------------------------
<S>      <C>           <C>          <C>        <C>         <C>        <C>          <C>       <C>        <C>         <C>
1               945      $100,000    $100,000   $100,000        $625      $669         $713        $-          $-         $-
2              1937      $100,000    $100,000   $100,000      $1,231    $1,358       $1,489      $330        $457       $588
3              2979      $100,000    $100,000   $100,000      $1,816    $2,063       $2,331      $915      $1,162     $1,430
4              4073      $100,000    $100,000   $100,000      $2,375    $2,783       $3,243    $1,474      $1,882     $2,342
5              5222      $100,000    $100,000   $100,000      $2,914    $3,522       $4,236    $2,013      $2,621     $3,335

6              6428      $100,000    $100,000   $100,000      $3,427    $4,275       $5,311    $2,706      $3,554     $4,590
7              7694      $100,000    $100,000   $100,000      $3,915    $5,042       $6,477    $3,374      $4,501     $5,937
8              9024      $100,000    $100,000   $100,000      $4,377    $5,825       $7,745    $4,017      $5,465     $7,385
9             10420      $100,000    $100,000   $100,000      $4,813    $6,622       $9,123    $4,633      $6,441     $8,942
10            11886      $100,000    $100,000   $100,000      $5,219    $7,430      $10,618    $5,219      $7,430    $10,618

11            13425      $100,000    $100,000   $100,000      $5,620    $8,286      $12,298    $5,620      $8,286    $12,298
12            15042      $100,000    $100,000   $100,000      $5,991    $9,159      $14,134    $5,991      $9,159    $14,134
13            16739      $100,000    $100,000   $100,000      $6,334   $10,049      $16,145    $6,334     $10,049    $16,145
14            18521      $100,000    $100,000   $100,000      $6,645   $10,956      $18,348    $6,645     $10,956    $18,348
15            20392      $100,000    $100,000   $100,000      $6,923   $11,878      $20,762    $6,923     $11,878    $20,762

16            22356      $100,000    $100,000   $100,000      $7,162   $12,811      $23,409    $7,162     $12,811    $23,409
17            24419      $100,000    $100,000   $100,000      $7,361   $13,753      $26,311    $7,361     $13,753    $26,311
18            26585      $100,000    $100,000   $100,000      $7,511   $14,699      $29,495    $7,511     $14,699    $29,495
19            28859      $100,000    $100,000   $100,000      $7,614   $15,649      $32,994    $7,614     $15,649    $32,994
20            31247      $100,000    $100,000   $100,000      $7,658   $16,594      $36,838    $7,658     $16,594    $36,838

Age 60        45102      $100,000    $100,000   $100,000      $6,836   $21,109      $62,886    $6,836     $21,109    $62,886
Age 65        62785      $100,000    $100,000   $118,793      $3,624   $24,752     $106,341    $3,624     $24,752   $106,341

</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 you should
not consider them to be a representation of past or future  investment  results.
Actual  investment  results  may be more or less  than  those  shown.  The death
benefit,  policy value and cash  surrender  value would be different  from those
shown if returns  averaged 0%, 6% and 12% over a period of years, but fluctuated
above and below those averages for individual  policy years. We cannot represent
that  these  hypothetical  rates of return can be  achieved  for any one year or
sustained over any period of time.


<PAGE>
<TABLE>
<CAPTION>

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

1          945       $100,000   $100,000  $100,000      $625      $669        $713       $-         $-         $-
2         1937       $100,000   $100,000  $100,000    $1,231    $1,358      $1,489     $330       $457       $588
3         2979       $100,000   $100,000  $100,000    $1,816    $2,063      $2,331     $915     $1,162     $1,430
4         4073       $100,000   $100,000  $100,000    $2,375    $2,783      $3,243   $1,474     $1,882     $2,342
5         5222       $100,000   $100,000  $100,000    $2,914    $3,522      $4,236   $2,013     $2,621     $3,335

6         6428       $100,000   $100,000  $100,000    $3,427    $4,275      $5,311   $2,706     $3,554     $4,590
7         7694       $100,000   $100,000  $100,000    $3,915    $5,042      $6,477   $3,374     $4,501     $5,937
8         9024       $100,000   $100,000  $100,000    $4,377    $5,825      $7,745   $4,017     $5,465     $7,385
9        10420       $100,000   $100,000  $100,000    $4,813    $6,622      $9,123   $4,633     $6,441     $8,942
10       11886       $100,000   $100,000  $100,000    $5,219    $7,430     $10,618   $5,219     $7,430    $10,618

11       13425       $100,000   $100,000  $100,000    $5,594    $8,248     $12,242   $5,594     $8,248    $12,242
12       15042       $100,000   $100,000  $100,000    $5,938    $9,077     $14,008   $5,938     $9,077    $14,008
13       16739       $100,000   $100,000  $100,000    $6,249    $9,915     $15,930   $6,249     $9,915    $15,930
14       18521       $100,000   $100,000  $100,000    $6,525   $10,760     $18,022   $6,525    $10,760    $18,022
15       20392       $100,000   $100,000  $100,000    $6,764   $11,611     $20,300   $6,764    $11,611    $20,300

16       22356       $100,000   $100,000  $100,000    $6,961   $12,462     $22,782   $6,961    $12,462    $22,782
17       24419       $100,000   $100,000  $100,000    $7,112   $13,310     $25,485   $7,112    $13,310    $25,485
18       26585       $100,000   $100,000  $100,000    $7,211   $14,149     $28,432   $7,211    $14,149    $28,432
19       28859       $100,000   $100,000  $100,000    $7,252   $14,973     $31,644   $7,252    $14,973    $31,644
20       31247       $100,000   $100,000  $100,000    $7,229   $15,776     $35,150   $7,229    $15,776    $35,150

Age 60   45102       $100,000   $100,000  $100,000    $5,934   $19,254     $58,392   $5,934    $19,254    $58,392
Age 65   62785       $100,000   $100,000  $117,459    $1,657   $20,822     $96,278   $1,657    $20,822    $96,278

</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 you should
not consider them to be a representation of past or future  investment  results.
Actual  investment  results  may be more or less  than  those  shown.  The death
benefit,  policy value and cash  surrender  value would be different  from those
shown if returns  averaged 0%, 6% and 12% over a period of years, but fluctuated
above and below those averages for individual  policy years. We cannot represent
that  these  hypothetical  rates of return can be  achieved  for any one year or
sustained over any period of time.

<PAGE>

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

         Not applicable.

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

         Not applicable.

58.      If the  trust is the  issuer of  periodic  payment  plan  certificates,
         furnish the following information for each installment type of periodic
         payment plan certificate outstanding as at the latest practicable date.

         Not applicable.

59.      Financial Statements:

         To be filed by amendment.

<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. **
                           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. **

<PAGE>
         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 filed as an
                           Exhibit for Policy 2 to Amendment No. 5 to the
                           Registration Statement to Form N-8B-2 File No.
                           811-05213.

                  (c)      Flexible Premium Variable Life Insurance: Schedules
                           of Sales and Commission to be filed by amendment.

         (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. **

                  (c)      Flexible Premium Life Insurance Policy to be filed by
                           amendment.

                  (d)      Waiver of Monthly Deduction Rider for Total
                           Disability to be filed by amendment.

                  (e)      Accidental Death Benefit Rider to be filed by
                           amendment.

                  (f)      Other Insured Rider to be filed by amendment.

                  (g)      Children's Level Term Insurance Rider to be filed by
                           amendment.

                  (h)      Automatic Increase Benefit Rider to be filed by
                           amendment.

         (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. **

                  (i)      Form of Participation Agreements to be filed by
                           amendment.

         (9)      None.

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

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

                  (c)      Application form for Flexible Premium Variable Life
                           Insurance Policy to be filed by amendment.

         (11)     Code of Ethics to be filed by amendment.

         (12)     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.*

         (13)     IDS Life of New York's  Description of Transfer and Redemption
                  Procedures and Method of Conversion to Fixed Benefit  Policies
                  to be filed by amendment.

<PAGE>

         (14)     Director's Power of Attorney dated April 14, 1999, filed as
                  Exhibit 9 to Post-Effective Amendment No. 1 to Registration
                  Statement, File No. 333-42257 is incorporated herein by
                  reference.

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 28th day of
August, 2000.


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:
     /s/ Mary Ellyn Minenko
         Mary Ellyn Minenko
         Counsel and Assistant Secretary
         IDS Life Insurance Company of New York


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

*Signed  pursuant to Directors'  Power of Attorney dated April 19, 1999 filed as
Exhibit 9 to Post-Effective Amendment No. 1 to Registration Statement,  File No.
33-42257.





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