IDS LIFE OF NEW YORK ACCOUNT SBS
485BPOS, 1995-04-28
Previous: AMERICAN ADJUSTABLE RATE TERM TRUST INC 1998, NSAR-A, 1995-04-28
Next: HARTFORD LIFE & ACCIDENT INS CO PUTNAM CAP MAN TR SEP AC ONE, POS AMI, 1995-04-28


 <PAGE>
PAGE 1
                  SECURITIES AND EXCHANGE COMMISSION

                        Washington, D.C.  20549

                               FORM N-4

REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933         X  

     Pre-Effective Amendment No.       

     Post-Effective Amendment No.   5    (File No. 33-45776)        
   
                                and/or

REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY 
ACT OF 1940                                                     X  

                Amendment No.   6   (File No. 811-6560)
                                   
                     IDS LIFE OF NEW YORK ACCOUNT SBS              
               (formerly IDS Life of New York Account SLB)
                        (Exact Name of Registrant) 

                 IDS Life Insurance Company of New York            
                           (Name of Depositor)

              20 Madison Avenue Extension, Albany, New York 12203  
    (Address of Depositor's Principal Executive Offices) (Zip Code)

Depositor's Telephone Number, including Area Code (612) 671-3678   

      Mary Ellyn Minenko, IDS Tower 10, Minneapolis, MN 55440-0010 
                (Name and Address of Agent for Service)

Approximate Date of Proposed Public Offering

It is proposed that this filing will become effective (check
appropriate box)
    immediately upon filing pursuant to paragraph (b) of Rule 485
 X  on May 1, 1995 pursuant to paragraph (b) of Rule 485
    60 days after filing pursuant to paragraph (a)(i) of Rule 485
    on (date) pursuant to paragraph (a)(i) of Rule 485
    75 days after filing pursuant to paragraph (a)(ii)
    on (date) pursuant to paragraph (a)(ii) of rule 485

If appropriate, check the following box:
    this post-effective amendment designates a new effective date
    for a previously filed post-effective amendment.

Calculation of Registration Fee Under the Securities Act of 1933

DECLARATION REQUIRED BY RULE 24f-2(a)(1)

The Registrant has registered an indefinite number or amount of
securities under The Securities Act of 1933 pursuant to Section 
24-f of the Investment Company Act of 1940.  Registrant's Rule 
24f-2 Notice for its most recent fiscal year was filed on or about
February 28, 1995.<PAGE>
PAGE 2
                         CROSS REFERENCE SHEET

Cross reference sheet showing location in the prospectus of the
information called for by the items enumerated in Part A and B of
Form N-4.

Negative answers omitted from prospectus are so indicated.
<TABLE><CAPTION>
          PART A                                                               PART B

                  Section                                                              Section in Statement of
  Item No.        in Prospectus                                        Item No.        Additional Information
     <S>          <C>                                                     <C>          <C>
     1            Cover                                                   15           Cover
                  
     2            Definitions                                             16           Table of Contents

     3(a)         Annuity and Certificate Expense                         17(a)        NA
      (b)         About the Annuity                                         (b)        NA
                                                                            (c)        Who Issues the Annuity*
     4(a)         Condensed Financial Information           
      (b)         Performance Information                                 18(a)        NA
      (c)         Financial Statements                                      (b)        NA
                                                                            (c)        Independent Auditors
     5(a)         Who Issues the Annuity                                    (d)        NA
      (b)         About the Annuity                                         (e)        NA
      (c)         About the Variable Account, Portfolios and Funds          (f)        NA
      (d)         Cover 
      (e)         Voting rights                                           19(a)        About the Annuity
      (f)         NA  
                                                                          20(a)        Principal Underwriter
     6(a)         Certificate Charges and Charges Against the Variable      (b)        Principal Underwriter
                    Account Annuity and Certificate Expenses                (c)        NA
      (b)         Surrender Charge                                          (d)        NA
      (c)         Calculation                                                                                       
      (d)         Surrendering Your Certificate                           21(a)        Performance Information       
      (e)         Investment Goals and Policies of the Portfolio and        (b)        Performance Information
                    and Funds
      (f)         NA                                                      22           
                                                                                                                     
     7(a)         Buying the Certificate                                  23(a)        Financial Statements
      (b)         About the Variable Account, Portfolios and the Funds;     (b)        Financial Statements
                    Transfering Your Money Between Accounts
      (c)         About the Variable Account, Portfolios and Funds;
                    Subaccounts Available for Investment
      (d)         Cover
 
     8(a)         Payout Options
      (b)         Retirement Date
      (c)         Payout Options
      (d)         Payout Options
      (e)         Payout Options
      (f)         Changing Ownership

     9(a)         Payment in Case of Death
      (b)         Payment in Case of Death

    10(a)         Buying the Certificate
      (b)         Settlement Value of Your Certificate
      (c)         Additional Information About the Annuity and
                    Certificate
      (d)         Who Issues the Annuity

    11(a)         Surrendering Your Certificate; Surrender Charges
      (b)         NA
      (c)         Receiving Payment When You Request a Surrender
      (d)         NA
      (e)         Ten Day Free Look

    12(a)         Taxes
      (b)         About the Variable Account, Portfolios and Funds
      (c)         Federal Tax Information
  <PAGE>
PAGE 3
    13            NA

    14            Table of contents of the Statement of Additional
                    Information
</TABLE>
*Designates page number in the prospectus, which is hereby
incorporated by reference in this Statement of Additional
Information. 
<PAGE>
PAGE 4
   
Symphony Annuity   
Prospectus/May 1, 1995
    
This prospectus describes interests in a master group flexible
premium deferred annuity (Annuity) and related certificates
(Certificates) offered by IDS Life Insurance Company of New York
(IDS Life of New York).  Individuals eligible to participate in the
Annuity include members of the general public.  Participation in
the Annuity will be accounted for separately by the issuance of a
Certificate showing your interest in the Annuity.  The Annuity is a
deferred group annuity in which purchase payments are accumulated
on a fixed and/or variable basis and which pays retirement benefits
to the Certificate owner.  The Annuity and related Certificates are
available for qualified and non-qualified retirement plans.  

IDS Life of New York Account SBS
Group Flexible Premium Deferred Combination Fixed and Variable
Annuity

Sold by:
   
IDS Life Insurance Company of New York 
20 Madison Avenue Extension 
P.O. Box 5144 
Albany, NY 12205 
Telephone: 800-336-3646
       
THIS PROSPECTUS IS VALID ONLY WHEN ACCOMPANIED OR PRECEDED BY THE
PROSPECTUS OF SMITH BARNEY SERIES FUND, IDS LIFE CAPITAL RESOURCE
FUND, IDS LIFE SPECIAL INCOME FUND, INC. AND IDS LIFE MANAGED FUND,
INC.  ALL PROSPECTUSES SHOULD BE RETAINED FOR FUTURE REFERENCE.
    
THESE SECURITIES HAVE NOT BEEN APPROVED OR DISAPPROVED BY THE
SECURITIES AND EXCHANGE COMMISSION OR ANY STATE SECURITIES
COMMISSION NOR HAS THE SECURITIES AND EXCHANGE COMMISSION OR ANY
STATE SECURITIES COMMISSION PASSED UPON THE ACCURACY OR ADEQUACY OF
THIS PROSPECTUS.  ANY REPRESENTATION TO THE CONTRARY IS A CRIMINAL
OFFENSE.
   
IDS LIFE OF NEW YORK IS NOT A FINANCIAL INSTITUTION, AND THE
SECURITIES IT OFFERS ARE NOT DEPOSITS OR OBLIGATIONS OF, OR
GUARANTEED OR ENDORSED BY ANY FINANCIAL INSTITUTION NOR ARE THEY
INSURED BY THE FEDERAL DEPOSIT INSURANCE CORPORATION, THE FEDERAL
RESERVE BOARD OR ANY OTHER AGENCY.
       
A Statement of Additional Information (SAI) dated May 1, 1995, as
amended and supplemented from time to time and incorporated herein
by reference, has been filed with the Securities and Exchange
Commission (SEC) and is available without charge by contacting IDS
Life of New York at the telephone number or address shown above.
       
The Table of Contents of the SAI appears on page 30 of this
prospectus.
    <PAGE>
PAGE 5
Definitions
  
Some terms used in this prospectus:

Accumulation Unit -- A measure of the value of your investment in
each of the subaccounts.  Prior to the retirement date, these units
are used to calculate the value of your Certificate.

Annuitant -- The person on whose life annuity payments depend. 
Calculation of annuity retirement payments depends on the
annuitant's age.

Certificate Value -- The total value of your Certificate before any
applicable surrender charge and any certificate charge have been
deducted.

Certificate Year -- A period of 12 months, starting on the
effective date of your Certificate and on each anniversary of the
effective date.

Fixed Account -- An additional account into which you may choose to
allocate purchase payments and which is included in your
certificate value.  Purchase payments allocated to the Fixed
Account will earn interest at a rate guaranteed by IDS Life of New
York which will change from time to time.

Owner (You, Your) -- The person or party owning the Certificate.

Payment Year -- Each certificate year in which you make a purchase
payment and each succeeding year measured from the end of the
certificate year during which you made such a payment.  For
example, if you make an initial purchase payment of $15,000 and
then make a subsequent purchase payment of $10,000 during the
fourth certificate year, the sixth certificate year will be the
sixth payment year with respect to your initial purchase payment
and the third payment year with respect to your subsequent purchase
payment.
   
Portfolios and Funds -- The Money Market Portfolio, Intermediate
High Grade Portfolio, Diversified Strategic Income Portfolio,
Equity Income Portfolio, Equity Index Portfolio, Growth & Income
Portfolio, Appreciation Portfolio, Total Return Portfolio,
International Equity Portfolio and Emerging Growth Portfolio
(collectively, the Portfolios), Capital Resource Fund, Special
Income Fund, and Managed Fund (collectively, the Funds).  
You may choose to allocate your purchase payments to one or more of
the subaccounts investing in shares of one of these Portfolios or
Funds, each of which is an open-end investment company or a series
of an open-end investment company registered under the Investment
Company Act of 1940, as amended (1940 Act).
    
Purchase Payments -- Payments made to IDS Life of New York for
purchase of a Certificate.

Retirement Date -- The date on which retirement payments begin.

<PAGE>
PAGE 6
Surrender Charge -- A deferred sales charge that may be applied if
you surrender your Certificate.

Surrender Value -- The total value of your Certificate after any
applicable surrender charge and any certificate charge have been
deducted.

Valuation Date -- Any normal business day, Monday through Friday,
except for the following holidays:  New Year's Day, Presidents'
Day, Good Friday, Memorial Day, Independence Day, Labor Day,
Thanksgiving Day and Christmas Day.
   
Variable Account -- IDS Life of New York Account SBS, a separate
account of IDS Life of New York.  Pursuant to the laws of the state
of New York, assets attributable to the Variable Account are held
by IDS Life of New York in one or more subaccounts.  Each
subaccount invests in a corresponding Portfolio or Fund.  The New
York Money Market subaccount invests in shares of the Money Market
Portfolio; the New York Intermediate High Grade subaccount invests
in shares of the Intermediate High Grade Portfolio; the New York
Diversified Strategic Income subaccount invests in shares of the
Diversified Strategic Income Portfolio; the New York Equity Income
subaccount invests in shares of the Equity Income Portfolio; the
New York Equity Index subaccount invests in shares of the Equity
Index Portfolio; the New York Growth & Income subaccount invests in
shares of the Growth & Income Portfolio; the New York Appreciation
subaccount invests in shares of the Appreciation Portfolio; the New
York Total Return subaccount invests in shares of the Total Return
Portfolio; the New York International Equity subaccount invests in
shares of the International Equity Portfolio; and the New York
Emerging Growth subaccount invests in shares of the Emerging Growth
Portfolio; the New York Capital Resource subaccount invests in
shares of the Capital Resource Fund; the New York Special Income
subaccount invests in shares of the Special Income Fund; and the
New York Managed subaccount invests in shares of the Managed Fund.
    
Summary of Contents
 
About the Annuity
   
Purpose of the Annuity -- The Annuity allows you to invest in any
or all of the thirteen subaccounts of the Variable Account as well
as in the Fixed Account.  Retirement payments are paid on a fixed
basis (page 13).
       
An Annuity or Certificate may be returned within 20 days after its
delivery for a full refund of the purchase payment (page 13).
       
Who Issues the Annuity -- IDS Life of New York, a subsidiary of IDS
Life Insurance Company (IDS Life), issues the Annuity (page 13).
       
About the Variable Account of the Portfolios and Funds
       
Subaccounts Available for Investment -- There are thirteen separate
subaccounts of the Variable Account available for investment in
addition to the Fixed Account (page 14).
    <PAGE>
PAGE 7
   
The Variable Account is registered as a single unit investment
trust under the 1940 Act (page 14).
       
Investment Goals and Policies of the Portfolios and Funds -- Each
Portfolio and Fund has a different investment goal.  The Money
Market Portfolio invests in high quality short-term money market
instruments.  The Intermediate High Grade Portfolio invests in
high-quality intermediate-term U.S. government securities and
corporate bonds of U.S. issuers.  The Diversified Strategic Income
Portfolio invests primarily in three types of fixed-income
securities -- U.S. government and mortgage securities, foreign
government bonds and corporate bonds rated below investment grade. 
The Equity Income Portfolio invests primarily in dividend-paying
common stocks, concentrating in securities of companies in the
utility industry.  The Equity Index Portfolio invests in the common
stocks of the companies represented in Standard & Poor's 500
Composite Stock Price Index (S&P 500).  The Growth & Income
Portfolio invests in dividend-paying equity securities meeting
certain specified investment criteria.  The Appreciation Portfolio
invests primarily in equity securities.  The Total Return Portfolio
invests primarily in a diversified portfolio of dividend-paying
common stocks.  The International Equity Portfolio invests at least
65 percent of its assets in a diversified portfolio of equity
securities of established non-U.S. issuers.  The Emerging Growth
Portfolio invests at least 65 percent of its total assets in common
stocks of small- and medium-sized companies, both domestic and
foreign, in the early stages of their life cycle.  The Capital
Resource Fund invests primarily in U.S. common stocks listed on
national securities exchanges and other securities convertible into
common stock, diversified over many different companies in a
variety of industries.  The Special Income Fund invests primarily
in high-quality, lower-risk corporate bonds issued by many
different companies in a variety of industries, and in government
bonds.  The Managed Fund invests primarily in U.S. common stocks
listed on national securities exchanges, securities convertible
into common stock, warrants, fixed income securities (primarily
high-quality corporate bonds) and money market instruments (page
15).
    
Using the Annuity and Certificates
   
Buying the Certificate -- Applications are subject to acceptance at
IDS Life of New York's home office in Albany (page 17).
       
IRAs and Other Qualified Plans -- Certificates may be issued in
connection with IRAs,  Tax-sheltered Annuities (TSAs) under 403(b)
plans, 401(k) plans and other qualified plans as well as in
connection with non-qualified retirement plans (page 17).
       
Purchase Payments -- You must make an initial lump sum purchase
payment for the Certificate and you may make additional purchase
payments.  The initial purchase payment must be at least $5,000 for
non-qualified Certificates and at least $500 for qualified 
Certificates.  After making the initial purchase payment, you may
make additional payments of at least $500 for non-qualified 
Certificates and at least $50 for qualified Certificates. 
Additional purchase payments can be mailed directly to IDS Life of <PAGE>
PAGE 8
New York.  The maximum total purchase payments for your Certificate
is $1,000,000.  IDS Life of New York reserves the right to increase
this maximum amount on a uniform basis for all Certificate owners
in a class (page 18).
       
Your purchase payments will be allocated to the Fixed Account
and/or to the subaccount(s) you choose.  For non-qualified
Certificates, the minimum value of your investment in a subaccount
or in the Fixed Account is $500.  This $500 minimum value does not
apply to qualified Certificates (page 18).
       
Transferring Your Money Between Accounts -- Until the retirement
date, you can give us written or telephone instructions to
redistribute your investment among the thirteen subaccounts of the
Variable Account.  There are some restrictions on transferring to
or from the Fixed Account.  Transfers must be for at least $500 or,
if less, your entire balance in the subaccount unless you establish
automated transfers of certificate values (page 18).
       
You may establish automated transfers of certificate values between
the subaccounts and/or the Fixed Account.  The minimum automated
transfer amount is $100.  This service is subject to restrictions
(page 18).
       
Certificate Charges and Charges Against the Variable Account -- IDS
Life of New York charges your Certificate $30 per year for
administrative services (page 19).  
       
IDS Life of New York charges the subaccounts of the Variable
Account a daily asset charge at an effective annual rate of 0.25
percent of the daily net asset value of the subaccounts for
administrative and operating expenses related to the subaccounts
(page 19).
       
IDS Life of New York charges the subaccounts of the Variable
Account a daily mortality and expense risk fee at an effective
annual rate of 1.25 percent of the daily net asset value of the
subaccounts (page 19).
       
A surrender charge applies if you make a full or partial surrender
of your certificate value during the first six payment years
following a purchase payment.  The surrender charge starts at 6
percent of a purchase payment in the first payment year and is
reduced by 1 percent each payment year thereafter.  There is no 
surrender charge after six payment years.  In addition, there is no
surrender charge when certificate values are applied to a
retirement payment plan or for a death benefit.  After the first
certificate year, each year you may surrender up to 10 percent of
your certificate value on your prior certificate anniversary
without incurring a surrender charge.  There also is no surrender
charge after the first certificate year on certificate earnings, as
defined herein (page 20).
       
The above charges will not increase during the term of the
Certificate.  For some sales, certain administrative and surrender
charges may be reduced or eliminated altogether (page 21).
    <PAGE>
PAGE 9
   
Surrendering Your Certificate -- You may surrender all or part of
your Certificate's value at any time before the retirement date. 
You will pay income tax on the taxable part of your surrender and a
10 percent IRS penalty tax may apply.  In addition, income tax
withholding at the rate of 20 percent may be imposed on surrenders
from Certificates purchased under certain qualified plans
(page 21).
       
The Internal Revenue Code of 1986, as amended (the Code) imposes
restrictions on your right to receive a distribution from a TSA
(page 22).
       
You may establish systematic withdrawals of up to 10 percent of the
certificate value at the beginning of the certificate year. 
Systematic withdrawals may be made in one of three ways (page 22).
       
A partial surrender must be for at least $500.  You cannot make a
surrender that would reduce the value of your investment in a
subaccount or in the Fixed Account to less than $500 unless the
value of your investment in a subaccount or in the Fixed Account is
fully withdrawn (page 23).
       
IDS Life of New York may ask you to return the Certificate if you
make a complete surrender (page 23).
       
Payment usually will be mailed within seven days after IDS Life of
New York receives your surrender request (page 23).
       
Payment in Case of Death before Retirement Payments Begin -- Prior
to the retirement date, if you or the annuitant die before the
initial fifth certificate anniversary, the beneficiary will be paid
the greater of: 1) the certificate value; or 2) the amount of
purchase payments (minus any surrenders).  On or after the initial
fifth certificate anniversary, and each subsequent fifth
certificate anniversary, the beneficiary will be paid the greater
of: 1) the certificate value; or 2) a minimum guaranteed death
benefit which equals: a) the death benefit calculated as of the
previous fifth certificate anniversary; plus b) any purchase
payments made since the previous fifth certificate anniversary;
minus c) any surrenders since the previous fifth certificate
anniversary (page 23).
       
In most cases, your spouse may keep the Certificate in force
(page 24).
       
Beneficiaries will receive payment in a single lump sum or may
request that payments be made under one of the retirement payment
plans IDS Life of New York offers (page 24).
       
Settlement Value of Your Certificate -- The amount available on the
retirement date to apply to a retirement payment plan equals the
then current certificate value (page 24).
       
IDS Life of New York calculates retirement payments due based on
the certificate value on the retirement date.  Payments are made on
a fixed basis (page 24).
    <PAGE>
PAGE 10
   
Payout Options at Retirement -- At retirement, you may choose one
of five payment plans or make other arrangements.  If you do not
choose one of the five payment plans, IDS Life of New York will
make payments under Plan B with 120 monthly payments guaranteed
(page 25).
       
If you purchased your Certificate in connection with a qualified
plan, the payment schedule must meet the requirements of that plan
(page 25).
       
If monthly payments would be less than $50, IDS Life of New York
reserves the right to reduce the frequency of the retirement
payments or to pay the certificate value in one lump sum payment
(page 25).
       
If you or the annuitant die after retirement payments begin, any
amount payable will be as provided in the retirement payment plan
in effect (page 25).
       
Changing Ownership -- You may change ownership of your Certificate
by filing a change of ownership form with IDS Life of New York. 
Certain restrictions apply concerning transfer of ownership of a
qualified Certificate, and certain transfers of non-qualified
Certificates may have adverse federal income tax consequences
(page 26).
       
Federal Tax Information -- According to current interpretations of
federal income tax law, there is no federal income tax on any
increase in the Certificate's value until payments are made. 
Consult your tax advisor (page 26).
       
If you surrender your Certificate or if retirement payments begin,
you will be taxed on the amount that exceeds your investment in the
Certificate.  Under certain circumstances, if you surrender all or
part of your Certificate or if retirement payments begin before you
reach age 59-1/2, a 10 percent IRS penalty tax may apply.  In
addition, 20 percent income tax withholding may be imposed on
distributions from Certificates purchased to fund qualified plans
including 401(k) plans and TSAs (but not IRAs) (page 27).
       
Additional Information about the Annuity and Certificates
       
Accumulation Units -- When your purchase payments are allocated to
a subaccount, they will be converted into accumulation units.  The
accumulation unit value increases or decreases with the performance
of the relevant Portfolio (page 27).
       
About the Portfolios and Funds -- As Certificate owner, you have
voting rights in the Smith Barney Series Fund and its Portfolios
and in the Funds.  IDS Life of New York may, in its discretion,
substitute investments in shares of the Portfolios and Funds with
shares of other registered investment companies under certain
conditions (page 28).
    
<PAGE>
PAGE 11
   
Information on the Fixed Account of the Annuity -- The Annuity also
allows you to allocate purchase payments to a Fixed Account where
they will earn interest at a rate guaranteed by IDS Life of New
York, which will change from time to time.  Subject to
restrictions, you may transfer certificate values from the Fixed
Account to the subaccounts and you may establish automated
transfers of certificate values between the Fixed Account and the
subaccounts.  Automated transfers from the Fixed Account may not
exceed an amount that, if continued, would deplete the Fixed
Account within 12 months.  This prospectus applies only to the
variable features of the Annuity.  Information about the Fixed
Account is found on page 29.
    
Annuity and Certificate Expenses
   
The following information is presented to help you understand the
various costs and expenses that you bear directly or indirectly as
the owner of a Certificate.  The information shows the expenses of
the Variable Account as well as the expenses of the underlying
Portfolios and Funds.  For more information about surrender
charges, see page 19.      
    
Annual Certificate Charges
                             Payment 
Surrender Charge               Year     Percentage           

(Contingent Deferred            1           6%
Sales Charge as a               2           5
percentage of purchase          3           4
payments)                       4           3
                                5           2
                                6           1
                           7 and later      0

Annual Certificate Administrative Charge        $30

Annual Variable Account Charges
Variable Account Administrative Charge  
(as a percentage of daily net asset value).......... 0.25%

Mortality and Expense Risk Fee 
(as a percentage of daily net asset value).......... 1.25%
Total Variable Account Annual Expenses.............. 1.50% 
   
Annual Operating Expenses of the Portfolios and Funds
(as a percentage of average daily net assets)
<TABLE><CAPTION>
______________________________________________________________________________________________________________________________
                           Intermedi-  Diversified
                 Money     ate High    Strategic    Equity   Equity  Growth                    Total    International  Emerging
                 Market    Grade       Income       Income   Index   & Income   Appreciation   Return   Equity         Growth
<S>              <C>       <C>         <C>          <C>     <C>      <C>
Management Fees    .50%        .60%         .65%      .65%    .60%     .65%        .73%          .75%     1.05%          .95%
Other Expenses     .25         .25          .30       .19     .40      .28         .13           .25       .25           .25
Total Operating
Expenses of
Portfolios#        .75%        .85%         .95%      .84%   1.00%     .93%        .88%         1.00%     1.30%         1.20%

<PAGE>
PAGE 12
Example*
You would pay the following expenses on a $1,000 investment, assuming (1) 5-percent annual return and (2) surrender at the end 
of each time period:

1 year         $ 83.69     $ 84.71      $ 85.70    $ 84.61 $ 86.23  $ 85.51     $ 85.01       $ 86.23   $ 89.28       $ 88.26
3 years        $113.22     $116.35      $119.00    $115.74 $121.06  $118.41     $116.93       $121.06   $130.47       $127.33
5 years        $145.76     $151.18      $154.93    $149.51 $159.27  $153.95     $151.49       $159.27   $175.46       $170.07
10 years       $271.64     $283.27      $287.13    $276.38 $300.73  $285.18     $280.31       $300.73   $323.52       $323.88

You would pay the following expenses on the same investment assuming no surrender or selection of a retirement payment plan at the
end of each time period:

1 year         $ 23.69     $ 24.71      $ 25.70    $ 24.61 $ 26.23  $ 25.51     $ 25.01       $ 26.23   $ 29.28       $ 28.26
3 years        $ 73.22     $ 76.35      $ 79.00    $ 75.74 $ 81.06  $ 78.41     $ 76.93       $ 81.06   $ 90.47       $ 87.33
5 years        $125.76     $131.18      $134.93    $129.51 $139.27  $133.95     $131.49       $139.27   $155.46       $150.07 
10 years       $271.64     $283.27      $287.13    $276.38 $300.73  $285.18     $280.31       $300.73   $323.52       $323.88

This example should not be considered a representation of past or future expenses.  Actual expenses may be more or less than 
those shown.

*In this example, the $30 annual certificate administrative charge is approximated as a .086 percent charge based on the
  expected average Certificate size.
</TABLE>
<TABLE><CAPTION>
                  Capital     Special
                  Resource    Income     Managed
<S>             <C>         <C>        <C>
Management Fees     .64%       .64%       .64%
Other Expenses      .04        .04        .04
- ------------------------------------------------
Total Operating
Expenses of Funds#  .68%       .68%       .68%

Example*
You would pay the following expenses on a $1,000 investment, assuming (1) 5-percent annual return and (2) surrender at the end of
each time period:

1 year           $84.83      $84.83     $84.83
3 years         $125.69     $125.69    $125.69
5 years         $156.76     $156.76    $156.76
10 years        $262.34     $262.34    $262.34

You would pay the following expenses on the same investment assuming no surrender or selection of a retirement payment plan at the
end of each time period:

1 year           $23.23      $23.23     $23.23
3 years          $71.56      $71.56     $71.56
5 years         $122.52     $122.52    $122.52
10 years        $262.34     $261.34    $261.34
</TABLE>
This example should not be considered a representation of past and
future expenses.  Actual expenses may be more or less than shown.

*In this example, the $30 annual contract administrative charge is
approximated as a .086 percent charge based on the expected average
Certificate size.

#Annualized operating expenses of underlying Mutual Funds at Dec.
31, 1994.
    
<PAGE>
PAGE 13
Condensed Financial Information (Unaudited)

The tables below give per-unit information about the financial
history of each subaccount.
   <TABLE><CAPTION>
                                                                                                  Period from
                                                                                Year ended         Mar. 15 to
                                                                             Dec. 31, 1994      Dec. 31, 1993
                                                                                                             
<S>                                                                                  <C>                <C>
Subaccount BMO (Investing in shares of Money Market Portfolio)*                    
Accumulation unit value at beginning of period............................           $1.01              $1.00
Accumulation unit value at end of period..................................           $1.03              $1.01
Number of accumulation units outstanding at end of period (000 omitted)...             539                450
Ratio of operating expense to average net assets..........................           1.50%              1.50%
Simple yield..............................................................           2.14%               .70%
Compound yield............................................................           2.16%               .70%

Subaccount BIH (Investing in shares of Intermediate High Grade Portfolio)*
Accumulation unit value at beginning of period............................           $1.03              $1.00
Accumulation unit value at end of period..................................           $0.98              $1.03
Number of accumulation units outstanding at end of period (000 omitted)...             734                733
Ratio of operating expense to average net assets..........................           1.50%              1.50%

Subaccount BDS (Investing in shares of Diversified Strategic Income Portfolio)*
Accumulation unit value at beginning of period............................           $1.06              $1.00
Accumulation unit value at end of period..................................           $1.02              $1.06
Number of accumulation units outstanding at end of period (000 omitted)...           2,866              2,055
Ratio of operating expense to average net assets..........................           1.50%              1.50%

Subaccount BEM (Investing in shares of Equity Income Portfolio)*
Accumulation unit value at beginning of period............................           $1.02              $1.00
Accumulation unit value at end of period..................................           $0.90              $1.02
Number of accumulation units outstanding at end of period (000 omitted)...           1,926              1,561
Ratio of operating expense to average net assets..........................           1.50%              1.50%

Subaccount BEX (Investing in shares of Equity Index Portfolio)*
Accumulation unit value at beginning of period............................           $1.03              $1.00
Accumulation unit value at end of period..................................           $1.02              $1.03
Number of accumulation units outstanding at end of period (000 omitted)...           1,274              1,128
Ratio of operating expense to average net assets..........................           1.50%              1.50%

Subaccount BGI (Investing in shares of Growth & Income Portfolio)*
Accumulation unit value at beginning of period............................           $1.05              $1.00
Accumulation unit value at end of period..................................           $1.00              $1.05
Number of accumulation units outstanding at end of period (000 omitted)...           1,820              1,335
Ratio of operating expense to average net assets..........................           1.50%              1.50%

Subaccount BAP (Investing in shares of Appreciation Portfolio)*
Accumulation unit value at beginning of period............................           $1.03              $1.00
Accumulation unit value at end of period..................................           $1.01              $1.03
Number of accumulation units outstanding at end of period (000 omitted)...           3,267              2,093
Ratio of operating expense to average net assets..........................           1.50%              1.50%

Subaccount BTR (Investing in shares of Total Return Portfolio)**
Accumulation unit value at beginning of period............................           $1.03              $1.00
Accumulation unit value at end of period..................................           $1.09              $1.03
Number of accumulation units outstanding at end of period (000 omitted)...             975                211
Ratio of operating expense to average net assets..........................           1.50%              1.50%

Subaccount BIE (Investing in shares of International Equity Portfolio)**
Accumulation unit value at beginning of period............................           $1.00              $1.00
Accumulation unit value at end of period..................................           $0.91              $1.00
Number of accumulation units outstanding at end of period (000 omitted)...           1,872                315
Ratio of operating expense to average net assets..........................           1.50%              1.50%

Subaccount BEG (Investing in shares of Emerging Growth Portfolio)**
Accumulation unit value at beginning of period............................           $1.04              $1.00
Accumulation unit value at end of period..................................           $0.95              $1.04
Number of accumulation units outstanding at end of period (000 omitted)...             706                148
Ratio of operating expense to average net assets..........................           1.50%              1.50%

<PAGE>
PAGE 14
                                                                                                  Period from
                                                                                Year ended         Mar. 15 to
                                                                             Dec. 31, 1994      Dec. 31, 1993
                                                                                                             

Subaccount BCR (Investing in shares of Life Capital Resource Fund)***
Accumulation unit value at beginning of period............................           $1.00                 --
Accumulation unit value at end of period..................................           $1.01                 --
Number of accumulation units outstanding at end of period (000 omitted)...               0                 --
Ratio of operating expense to average net assets..........................           1.50%                 --

Subaccount BSI (Investing in shares of Life Special Income Fund)***
Accumulation unit value at beginning of period............................           $1.00                 --
Accumulation unit value at end of period..................................           $0.99                 --
Number of accumulation units outstanding at end of period (000 omitted)...               0                 --
Ratio of operating expense to average net assets..........................           1.50%                 --

Subaccount BMG (Investing in shares of Life Managed Fund)***
Accumulation unit value at beginning of period............................           $1.00                 --
Accumulation unit value at end of period..................................           $0.99                 --
Number of accumulation units outstanding at end of period (000 omitted)...               0                 --
Ratio of operating expense to average net assets..........................           1.50%                 --

*Operations commenced on Mar. 15, 1993.
**Operations commenced on Dec. 2, 1993.
***Operations commenced on Nov. 28, 1994.
</TABLE>    
Financial Statements
   
Complete financial statements of the Variable Account including
audited individual and combined statements of net assets as of Dec.
31, 1994, and the related statements of operations for the year
then ended, and the related statement of changes in net assets for
the period from March 15, 1993 (commencement of operations) to Dec.
31, 1993, except for BTR, BEG and BIE subaccounts which are for the
year ended Dec. 31, 1994 and the period Dec. 2, 1993 (commencement
of operations) to Dec. 31, 1993 and the BCR, BSI and BMG
subaccounts which are for the period Nov. 28, 1994 (commencement of
operations) to Dec. 31, 1994, are presented in the SAI dated May 1,
1995.  The audited financial statements of IDS Life Insurance
Company of New York including audited balance sheets as of Dec. 31,
1994, and 1993, and audited related statements of income and cash
flows for each of the three years in the period ended Dec. 31, 1994
also are presented in the SAI.
    
Performance Information

Yield 
   
Performance information for the subaccounts of the Variable
Account, including the simple yield and effective yield for the New
York Money Market subaccount, and yield and total return for the
remaining subaccounts, may appear from time to time in
advertisements or sales literature.
    
The simple yield of the New York Money Market subaccount is based
on income received by a hypothetical investment over a given
seven-day period (less expenses accrued during the period); and
then "annualized" by assuming that the seven-day yield would be
received for 52 weeks and is stated in terms of an annual
percentage return on the investment.  The effective yield of the
New York Money Market subaccount is calculated in a manner similar
to that used to calculate simple yield.  However, when annualized,
the income earned by the investment is assumed to be reinvested.  <PAGE>
PAGE 15
The effective yield will be slightly higher than the simple yield
due to the compounding effect of this assumed reinvestment.
   
Yield quotations for remaining subaccounts are based on all
investment income per accumulation unit earned during a given
30-day period, less expenses accrued during the period (net
investment income).  Yield quotations are computed by dividing this
net investment income by the value of an accumulation unit on the
last day of the period.  
    
Total Return 
   
Average annual total return quotations will be expressed in terms
of the average annual compounded rate of return of a hypothetical
investment in a Certificate over a period of one, five and 10 years
(or, if less, up to the life of the subaccount).  The average
annual total return quotations will reflect the deduction of all
applicable charges including the administrative charge, the
Variable Account administrative charge and the mortality and
expense risk fee.  Quotations will be made that reflect the
deduction of the applicable surrender charge (assuming a surrender
at the end of the illustrated period).  Additional average annual
total return quotations may be made that do not reflect a surrender
charge deduction (assuming no surrender at the end of the
illustrated period).  A subaccount also may use aggregate total
return figures for various periods, representing the cumulative
change in the value of an investment in the subaccount for the
specific period (again reflecting changes in a subaccount's
accumulation unit value and assuming reinvestment of investment
earnings).  Aggregate total returns may be shown by means of
schedules, charts or graphs.
    
Performance information reflects only the performance of a
hypothetical investment in the subaccount during the particular
time period on which the calculations are based.  Performance
information should be considered in light of the investment
objectives and policies, characteristics and quality of the
Portfolio of the Fund in which the subaccount invests, and the
market conditions during the given time period and is not intended
to indicate future performance.  Advertised yields and total return
figures for the subaccounts include all charges attributable to the
Certificate which have the effect of decreasing the advertised
performance of a subaccount.  For this reason, performance
information for a subaccount should not be compared to that for
mutual funds that sell their shares directly to the public.  See
the SAI for a description of the methods used to determine yield
and total return information for the subaccounts.

About the Annuity
  
Purpose of the Annuity
   
The goal of the Annuity is to allow you, the Certificate owner, to
build up funds for retirement.  You do this by investing in any one
or more of thirteen subaccounts of the Variable Account or in the
Fixed Account.  Each subaccount invests only in shares of a single
Portfolio or Fund.  You can direct payments to go to anyone, but <PAGE>
PAGE 16
you will still be taxed on the income as owner.  You can choose
from a variety of retirement payment plans.
       
The Annuity is a variable annuity.  A variable annuity differs from
a fixed annuity in that during the accumulation period, the
certificate value may vary from day to day.  You assume the risk of
gain or loss according to the performance of your investment. 
There is no guarantee that your Certificate's value at the
retirement date will equal or exceed the total of your purchase
payments.  Read this prospectus carefully to decide if a variable
annuity will help meet your retirement goals.  You also must read
the accompanying separate prospectuses describing the Portfolios
and the Funds to help you decide on the best investments for your
needs.  Keep these prospectuses for future reference.
       
An Annuity or Certificate may be returned within 20 days after its
delivery for a full refund of the purchase payment.  Return it to
your Smith Barney Financial Consultant or mail it to IDS Life of
New York's home office at the address on the cover page of this
prospectus.  No fees or charges will be deducted.
    
Who Issues the Annuity
   
IDS Life Insurance Company of New York issues the Annuity.  IDS
Life of New York is a wholly owned subsidiary of IDS Life, which
itself is a wholly owned subsidiary of American Express Financial
Corporation.  American Express Financial Corporation is a wholly
owned subsidiary of the American Express Company.  American Express
Company is a financial services company principally engaged through
subsidiaries (in addition to American Express Financial
Corporation) in travel related services, international banking
services, financial services and portfolio management advice.
    
IDS Life of New York is a stock life insurance company organized in
1972 under the laws of the State of New York.  Its home office is
at 20 Madison Avenue Extension, Albany, New York and its mailing
address is P.O.  Box 5144, Albany, NY 12205.  IDS Life of New York
is licensed in New York and North Dakota and it conducts a
conventional life insurance business in the State of New York.
   
Smith Barney Inc., a Delaware corporation, is the principal
underwriter of the Variable Account.  Its home office is 388
Greenwich Street, New York, New York 10013.  Smith Barney Inc. is a
wholly owned subsidiary of Smith Barney (Holdings) and an indirect
wholly-owned subsidiary of The Travelers Inc.  The Travelers Inc.
is a diversified financial services holding company principally
engaged in the business of providing investment, consumer finances
and insurance services.
       
About the Variable Account, the Portfolios and the Funds
    
Subaccounts Available for Investment
   
You may choose to invest your purchase payments in any or all of
thirteen subaccounts or in the Fixed Account.  Each of the
subaccounts invests only in a single Portfolio or Fund:
    <PAGE>
PAGE 17
   
o The New York Money Market subaccount (BMO) invests in shares of
the Money Market Portfolio; 

o The New York Intermediate High Grade subaccount (BIH) invests in
shares of the Intermediate High Grade Portfolio;

o The New York Diversified Strategic Income subaccount (BDS)
invests in shares of the Diversified Strategic Income Portfolio;

o The New York Equity Income subaccount (BEM) invests in shares of
the Equity Income Portfolio;

o The New York Equity Index subaccount (BEX) invests in shares of
the Equity Index Portfolio;

o The New York Growth & Income subaccount (BGI) invests in shares
of the Growth & Income Portfolio;

o The New York Appreciation subaccount (BAP) invests in shares of
the Appreciation Portfolio;

o The New York Total Return subaccount (BTR) invests in shares of
the Total Return Portfolio;

o The New York International Equity subaccount (BIE) invests in
shares of the International Equity Portfolio; and

o The New York Emerging Growth subaccount (BEG) invests in the
shares of the Emerging Growth Portfolio.

o The New York Capital Resource subaccount (BCR) invests in shares
of the Capital Resource Fund.

o The New York Special Income subaccount (BSI) invests in shares of
the Special Income Fund.

o The New York Managed subaccount (BMG) invests in shares of the
Managed Fund.
       
Income, capital gains and capital losses of each subaccount are
credited or charged to that subaccount alone.  No subaccount will
be charged with liabilities or expenses of any other subaccount or
of IDS Life of New York's general business.  All obligations
arising under the certificates are general obligations of IDS Life
of New York.
    
The Variable Account was established on October 8, 1991 under New
York law.  On Oct. 14, 1993 the name of the Variable Account was
changed from IDS Life of New York Account SLB to IDS Life of New
York Account SBS.  The Variable Account is registered as a single
unit investment trust under the 1940 Act.  The Variable Account
meets the definition of a separate account under the federal
securities laws.  This registration does not involve any
supervision by the SEC of IDS Life of New York's management or
investment practices and policies.

<PAGE>
PAGE 18
   
The Internal Revenue Service (IRS) has issued final regulations
relating to the diversification requirements under section 817(h)
of the Code.  Each Portfolio and Fund intends to comply with those
diversification requirements.  See the accompanying prospectuses
for further tax information regarding the Portfolios and Funds.
    
The U.S. Treasury and the IRS have been developing a revenue ruling
concerning investment control.  The ruling may address the number
of subaccounts offered under an annuity and the number of exchanges
among the subaccounts that would be allowed before an annuity or
certificate owner would be considered to have investment control
and thus would be currently taxed on the income earned on the
underlying portfolio assets.  This issue is still being studied by
the IRS and the timing of further action is unknown.  IDS Life of
New York reserves the right to modify the Annuity and related
Certificates, as necessary, to prevent the Annuity or Certificate
owner from being currently taxed as the owner of the underlying
assets of the Variable Account for federal income tax purposes.

IDS Life of New York intends to comply with all U.S. Treasury
guidance to insure that the Annuity continues to qualify as an
annuity for federal income tax purposes.
   
Investment Goals and Policies of the Portfolios and Funds  
       
The investment goals of the Portfolios and Funds are as follows:
    
The Money Market Portfolio's goal is maximum current income to the
extent consistent with the preservation of capital and the
maintenance of liquidity.  In seeking to achieve its goal, the 
Portfolio will invest in short-term money market instruments deemed
to present minimal credit risks and considered to be "Eligible
Securities" as defined by the SEC.

The Intermediate High Grade Portfolio's goal is to provide as high
a level of current income as is consistent with the protection of
capital.  In seeking to achieve its goal, the Portfolio will
invest, under normal market conditions, substantially all, but not
less than 65 percent, of its assets in U.S. government securities
and in high grade corporate bonds of U.S. issuers (i.e., bonds
rated within the two highest rating categories by Moody's Investors
Service, Inc. or Standard & Poor's Corporation or, if not rated,
bonds believed to be of comparable quality).
   
The Diversified Strategic Income Portfolio's goal is high current
income.  In seeking to achieve its goal, the Portfolio will
allocate and reallocate its assets primarily among three types of
fixed-income securities -- U.S. government and mortgage related 
securities, foreign government bonds and corporate bonds rated
below investment grade (commonly known as junk bonds).  See the 
section of the Smith Barney Series Fund's prospectus entitled
"Medium-, Lower- and Unrated Securities" for further information on
these bonds.  
    
The Equity Income Portfolio's primary goal is current income. 
Long-term capital appreciation is a secondary goal.  In seeking to <PAGE>
PAGE 19
achieve its goals, the Portfolio will invest principally in
dividend-paying common stocks of companies whose prospects for
dividend growth and capital appreciation are considered favorable,
concentrating its investments in the utility industry.

The Equity Index Portfolio's goal is to provide investment results
that, before deduction of operating expenses, match the price and
yield performance of U.S. publicly traded common stocks, as
measured by the S&P 500.  Once the Portfolio reaches a sufficient
asset size, it will seek to achieve its goal by owning all 500
stocks in the S&P 500 in proportion to their actual market
capitalization weightings.

The Growth & Income Portfolio's goal is income and long-term
capital growth.  In seeking to achieve its goal, the Portfolio will
invest in income-producing equity securities, including dividend
paying common stocks, securities that are convertible into common
stocks and warrants meeting certain specified investment criteria.

The Appreciation Portfolio's goal is long-term appreciation of
capital.  In seeking to achieve its goal, the Portfolio will invest
primarily in equity and equity-related securities that are believed
to afford attractive opportunities for appreciation.

The Total Return Portfolio's goal is to provide shareholders with
total return, consisting of long-term capital appreciation and
income.  In seeking to achieve its goal, the Portfolio will
primarily invest in a diversified portfolio of dividend-paying
common stocks.

The International Equity Portfolio's goal is to provide a total
return on its assets from growth of capital and income.  In seeking
to achieve its goal, under normal market conditions the Portfolio
will invest at least 65% of its assets in a diversified portfolio
of equity securities of established non-United States issuers.

The Emerging Growth Portfolio's goal is to provide capital
appreciation.  In seeking to achieve its goal, the Portfolio will
invest at least 65% of its total assets in common stocks of small-
and medium-sized companies, both domestic and foreign, in the early
stages of their life cycle, that its investment adviser believes
have the potential to become major enterprises.
   
The Capital Resource Fund's goal is capital appreciation.  In
seeking to achieve its goal, the Fund will invest primarily in U.S.
common stocks listed on national securities exchanges and other
securities convertible into common stock, diversified over many
different companies in a variety of industries.

The Special Income Fund's goal is to provide a high level of
current income while conserving the value of the investment for the
longest period of time.  In seeking to achieve its goal, the Fund
will invest primarily in high-quality, lower-risk corporate bonds
issued by many different companies in a variety of industries, and
in government bonds.

<PAGE>
PAGE 20
The Managed Fund's goal is maximum total investment return.  In
seeking to achieve its goal, the Fund will invest primarily in U.S.
common stocks listed on national securities exchanges, securities
convertible into common stock, warrants, fixed income securities
(primarily high-quality corporate bonds) and money market
instruments.  The Fund invests in many different companies in a
variety of industries.
       
IDS Life of New York does not guarantee that the Portfolios and
Funds will meet their investment goals.  Whether they achieve their
goals depends on a number of factors including their managements'
ability to manage the risks of changing economic conditions.
    
The organizations that perform services for the Portfolios are
listed below:
   <TABLE><CAPTION>
               Name                            Service             
<S>                                <C>
American Capital Asset             Investment Adviser to the
Management, Inc.                   Emerging Growth Portfolio

American Express Financial         Investment Advisor to Capital
Corporation                        Resource, Special Income and
                                   Managed Funds

IDS Life Insurance Company         Investment Manager to Capital
                                   Resource, Special Income and
                                   Managed Funds

Smith Barney Global Capital        Sub-Investment Adviser to the
Management, Inc.                   Diversified Strategic Income
                                   Portfolio

Smith Barney Mutual Funds          Investment Adviser to the Money
Management, Inc.                   Market Portfolio, the
                                   Intermediate High Grade
                                   Portfolio, the Diversified
                                   Strategic Income Portfolio, the
                                   Equity Income Portfolio, the
                                   Growth & Income Portfolio, the 
                                   Appreciation Portfolio, the 
                                   Total Return Portfolio and the 
                                   International Equity Portfolio 
                                   and Administrator to each 
                                   Portfolio

Travelers Investment Management    Investment Adviser to the Equity
Company                            Index Portfolio                 

Boston Safe Deposit and Trust      Custodian
Company     

The Shareholder Services Group,    Transfer and Dividend Paying
Inc., a subsidiary of First Data   Agent
Corporation                                                        

Smith Barney Inc.                  Distributor                     
</TABLE>    <PAGE>
PAGE 21
   
Detailed information about each Portfolio and Fund, including the
risks related to investing in them is in the separate prospectuses. 
Be sure to read them carefully.  There are deductions from, and
fees and expenses paid out of, the assets of the Portfolios and
Funds that are described in these prospectuses.
    
Using the Annuity and Certificate
 
Buying the Certificate 
   
Your Smith Barney Financial Consultant will help you prepare your
application, which will be sent with your purchase payment to IDS
Life of New York's home office in Albany.  If your application is
complete, IDS Life of New York will apply your payment as of the
next close of business after it is received.  If IDS Life of New
York cannot accept your application within five days, it will be
declined and your payment will be returned to you.
    
When IDS Life of New York accepts your application, a Certificate
will be sent to you.

When you apply for the Certificate, you can select the Fixed
Account and/or the subaccount(s) in which you wish to invest and
the amounts to be allocated to each.  You also select how you wish
to make purchase payments.  Your purchase payments will be
allocated to the Fixed Account and/or the subaccount(s) according
to your election as of the next close of business after your
payment is received.

IDS Life of New York reserves the right to impose a maximum issue
age for non-qualified Certificates of age 75 and a maximum issue
age for qualified Certificates of age 65.

Ownership -- As owner, you have all rights and may receive all
benefits under the Certificate.  The Certificate can be owned in
joint tenancy only in spousal situations.

Retirement Date -- A retirement date is established when you apply
for the Certificate.  If you need to change it, send written
instructions to IDS Life of New York's home office at least 30 days
before you wish the change to become effective.

For non-qualified Certificates, the retirement date cannot be later
than the annuitant's 85th birthday or 10 years after issue,
whichever is later.

If you are buying this Certificate to fund a Section 401(k) plan,
custodial or trusteed plan, IRA or TSA plan, to avoid penalty
taxes, retirement payments generally must not begin earlier than
the date the annuitant turns 59-1/2 or later than April 1 of the
year following the calendar year in which he or she reaches age 
70-1/2.  However, in no case can the retirement date be later than
the annuitant's 85th birthday or 10 years after issue, whichever is
later.
<PAGE>
PAGE 22
Naming a Beneficiary -- You may name a beneficiary under your
Certificate.  If the annuitant dies before the retirement date and
there is no beneficiary, then you will be the beneficiary.  If you
die before the retirement date and there is no beneficiary, then
your estate will be the beneficiary.

IRAs and Other Qualified Plans

The Certificate may be bought in connection with a retirement plan
qualified under Sections 401, 403 or 408 of the Code.  These plans
include:

o IRAs and Simplified Employee Pension plans (SEPs);

o Custodial and trusteed pension and profit sharing plans;

o Section 401(k) plans; and

o Section 403(b) plans (TSAs).

Your purchase of the Certificate in connection with a qualified
plan will be subject to applicable federal law and any rules of the
plan itself.  

Purchase Payments

Amount of Purchase Payments -- You must make an initial lump sum
purchase payment for the Certificate and you may make additional
purchase payments for the Certificate.  The initial purchase
payment must be at least $5,000 for non-qualified Certificates and
at least $500 for qualified Certificates.  After making the initial
purchase payment, you may make additional payments of at least $500
for non-qualified Certificates and at least $50 for qualified
Certificates.  Additional purchase payments can be mailed directly
to IDS Life of New York.  The maximum total purchase payments for
your Certificate in the first and later years is $1,000,000.  IDS
Life of New York reserves the right to increase this maximum amount
on a uniform basis for all Certificate owners in a class.

Qualified Plans -- If you invest in the Certificate in connection
with a qualified plan, that plan's limits on annual contributions
also will apply.

Allocating your Purchase Payments -- Your purchase payment(s) will
be allocated to the Fixed Account and/or the subaccount(s) you have
selected as of IDS Life of New York's next close of business
currently the same as the close of the New York Stock Exchange 
(NYSE) after IDS Life of New York receives your payment.  For
non-qualified Certificates, the minimum value of your investment in
a subaccount or in the Fixed Account is $500.  This $500 minimum
does not apply to qualified Certificates.

Transferring Your Money Between Accounts

Prior to retirement, you may make unlimited transfers of your money
from one subaccount to another by making a written request.  There <PAGE>
PAGE 23
are some restrictions on transferring to or from the Fixed Account
as discussed in the section called "Information on the Fixed
Account of the Annuity."  IDS Life of New York will make the
transfer at its next close of business.  There is no charge for
transfers.  However, unless the transfer is an automated transfer
described below, IDS Life of New York does require that your
transfer be for:

o at least $500; or

o your entire balance in that subaccount, if less.

Automated Transfers -- You may establish automated transfers of
certificate values between the subaccounts and/or the Fixed Account
through a one-time written request or other method acceptable to
IDS Life of New York.  The minimum automated transfer amount is
$100.  Such transfers may be made on a monthly, quarterly,
semi-annual or annual basis.  You may start or stop this service at
any time, but you must give IDS Life of New York 30 days' notice to
change any automated transfer instructions that are currently in
place.  Automated transfers are subject to all of the other Annuity
provisions and terms, including provisions relating to the transfer
of money between subaccounts.

For information on restrictions on automated transfers of
certificate values between the Fixed Account and the subaccounts
see the section called "Information on the Fixed Account of the
Annuity."

Before transferring any part of your certificate value, you should
consider the risks involved in switching investments.  IDS Life of
New York may, in its sole discretion and subject to regulatory
approval, suspend or modify these transfer privileges at any time.

Telephone Transfers -- You also may request a transfer by
telephone.  IDS Life of New York has the authority to honor any
telephone requests believed to be authentic and will use reasonable
procedures to confirm that they are.  This includes asking
identifying questions and tape recording calls.  As long as the
procedures are followed, neither IDS Life of New York nor its
affiliates will be liable for any loss resulting from fraudulent
requests.  If IDS Life of New York receives your transfer request 
before its close of business (normally 4 p.m. Eastern time), it
will be processed that day.  Calls received after its close of
business will be processed the next business day.  At times when
the volume of telephone requests is unusually high, IDS Life of New
York will take special measures to seek to ensure that your call is
answered as promptly as possible.  A telephone transfer request
will not be allowed within 30 days of a phoned-in address change.

You may request that telephone transfers not be authorized from
your account by writing IDS Life of New York.

Certificate Charges and Charges Against the Variable Account

<PAGE>
PAGE 24
Certificate Administrative Charge -- IDS Life of New York charges
your Certificate an administrative fee of $30 each year.  This
charge is for establishing and maintaining your records.  IDS Life
of New York deducts it from the certificate value on each
certificate anniversary.  If you fully surrender your Certificate,
IDS Life of New York will deduct a reduced certificate
administrative charge that is prorated based on the number of days
from your last certificate anniversary to the date of full
surrender.  The certificate administrative charge cannot be
increased and does not apply after a retirement payment plan
begins.  IDS Life of New York does not expect to profit from the
certificate administrative charge.

Variable Account Administrative Charge -- This charge is deducted
daily from the subaccounts of the Variable Account.  The charge
equals an effective annual rate of 0.25 percent of the daily net
asset value of the subaccounts and is paid to IDS Life of New York.

It covers certain administrative and operating expenses of the
subaccounts incurred by IDS Life of New York such as accounting,
legal and data processing fees, and expenses involved in the
preparation and distribution of reports and prospectuses.  The
Variable Account administrative charge cannot be increased and does
not apply after a retirement payment plan begins.  IDS Life of New
York does not expect to profit from the Variable Account
administrative charge.

Mortality and Expense Risk Fee -- This charge is deducted daily
from the subaccounts of the Variable Account.  The charge equals an
effective annual rate of 1.25 percent of the daily net asset value
of the subaccounts and is paid to IDS Life of New York.  It covers
IDS Life of New York's annuity mortality risk and expense risk. 
IDS Life of New York estimates that approximately two-thirds of
this fee is for assumption of the mortality risk, and one-third is
for assumption of the expense risk.

The mortality risk arises from IDS Life of New York's guarantee to
make retirement payments according to the terms of the Certificate
no matter how long a specific annuitant lives and no matter how
long the entire group of IDS Life of New York annuitants live.  If,
as a group, IDS Life of New York annuitants outlive the life
expectancy that has been assumed in the actuarial tables,  IDS Life
of New York must take money from its general assets to meet its 
obligations.  If, as a group, IDS Life of New York annuitants do
not live as long as expected, IDS Life of New York could profit
from the mortality risk fee.

The expense risk is the risk that the certificate administrative
charge and Variable Account administrative charge, which cannot be
increased, will not cover IDS Life of New York's expenses.  Any
deficit would have to be made up from IDS Life of New York's
general assets.  IDS Life of New York could profit from the expense
risk fee if the annual administrative charges exceed expenses. 
Although IDS Life of New York does not expect to profit from the 
administrative charges,  IDS Life of New York does expect to profit
<PAGE>
PAGE 25
from the mortality and expense risk fee.  Any profit realized by
IDS Life of New York from this fee would be available to it for any
proper corporate purpose, including, among other things, payment of
distribution (selling) expenses.  IDS Life of New York does not
expect that the surrender charge, which is discussed in the
following paragraphs, will cover sales and distribution expenses
incurred by IDS Life of New York in connection with the
Certificates.

Surrender Charges -- If you surrender part or all of your
Certificate, you may be subject to a surrender charge.  A surrender
charge applies if all or part of the certificate value is
surrendered during the first six payment years following a purchase
payment.  The surrender charge starts at 6 percent of a purchase
payment in the first payment year and is reduced by 1 percent each
payment year thereafter.  This means that there is no surrender
charge after six payment years.  In addition, there is no surrender
charge when certificate values are applied to a retirement payment
plan or for a death benefit.  The surrender charge is used to help
defray expenses incurred in the sale of the Certificates including
commissions and other promotional or distribution expenses
associated with the printing and distribution of prospectuses and
sales material.

After the first certificate year, you may surrender up to 10
percent of your prior certificate anniversary value in one or more
surrenders each certificate year without incurring a surrender
charge.  The 10 percent free withdrawal provision is subject to
other Annuity provisions and terms including those on partial
surrenders.

In addition, after the first certificate year there is no surrender
charge on certificate earnings, which equal:

1) the certificate value at the time of surrender; minus

2) the sum of all purchase payments received that have not been
previously surrendered; minus

3) the amount of the 10 percent free withdrawal, if applicable.

For purposes of determining the amount of any surrender charge,
surrenders will be deemed to be taken first from any applicable 10 
percent free withdrawal amount; next, from certificate earnings (in
excess of any 10 percent free withdrawal amount); and finally from
purchase payments (on a first in-first out basis).  

Surrender Charge Calculation -- The following example illustrates
how the surrender charge is calculated:

Assumptions:
   <TABLE><CAPTION>
<S>                                                                                    <C>
______________________________________________________________________________________________
Initial purchase payment at Certificate issue date of May 1, 1995 .................... $10,000 
Subsequent purchase payment on July 1, 1998...........................................  20,000 
Account value on Certificate anniversary on May 1, 1999 ..............................  40,000
Account value on October 12, 1999.....................................................  42,000
______________________________________________________________________________________________
</TABLE>    
<PAGE>
PAGE 26
   <TABLE><CAPTION> 
Full Surrender on October 12, 1999:

Basis of        Rate of               Dollar Amount 
Charge          Surrender Charge      of Charge             Explanation of Charge                                                 
<S>                  <C>                   <C>              <C>                    
$ 4,000              None                  $    0           10% of certificate value surrendered free
$ 8,000              None                  $    0           No charge on certificate earnings
$10,000              2%                    $  200           Payment made in certificate year 1; surrendered at payment year 5 rate
$20,000              5%                    $1,000           Payment made in certificate year 4; surrendered at payment year 2 rate
Total Surrender Charge:                    $1,200

Partial Surrender of $25,000 on October 12, 1999:
__________________________________________________________________________________________________________________________________
Basis of        Rate of               Dollar Amount of   
Charge          Surrender Charge      Charge                Explanation of Charge                                                 
$ 4,000              None                  $    0           10% of certificate value surrendered free
$ 8,000              None                  $    0           No charge on certificate earnings
$10,000              2%                    $  200           Payment made in certificate year 1; surrendered at payment year 5 rate
$ 3,000              5%                    $  150           Payment made in certificate year 4; surrendered at payment year 2 rate
Total Surrender Charge:                    $  350  
</TABLE>    
Surrender Charge on Partial Surrender -- The surrender charge is
deducted from the certificate value remaining after the owner is
paid the partial surrender amount requested.  For example, if the
owner requested a partial surrender net check amount of $1,000 and
the surrender charge rate that applied to that amount were 5
percent, the owner would receive the $1,000 requested and the
surrender charge amount would be $52.63 for a total withdrawal of
$1,052.63.

Possible Reduction in Charges -- In some cases,  IDS Life of New
York may expect to incur lower sales and administrative expenses or
perform fewer services.  In those cases,  IDS Life of New York may,
in its discretion, reduce or eliminate certain administrative and
surrender charges.  However, IDS Life of New York expects this to
occur infrequently, if at all.

Surrendering Your Certificate

As owner, you may surrender all or part of your Certificate's value
at any time before the retirement date by making a written request.

You may have to pay surrender charges as previously explained. 
Also, if you fully surrender your Certificate, a prorated portion
of the certificate administrative charge based on the number of
days from your last certificate anniversary to the date of full
surrender will be deducted at the time of surrender.  No surrenders
may be made after the retirement date.

You may have to pay a 10 percent IRS penalty tax for surrenders
made before you reach age 59-1/2.  In addition, if you purchased
the Certificate in connection with a qualified plan such as a
401(k) plan or a TSA (but not an IRA) and amount surrendered is 
paid to you instead of being directly rolled over to an IRA or
another eligible qualified plan, 20 percent income tax withholding 
may be imposed.  See the section called "Federal Tax Information."
Finally, certain restrictions may apply to participants in TSA
plans.  See the section called "Tax-Sheltered Annuities."

Tax-Sheltered Annuities -- The Code imposes certain restrictions on
an owner's right to receive early distributions attributable to
salary reduction contributions from a Certificate purchased in<PAGE>
PAGE 27
connection with a retirement plan qualified under Section 403(b) as
a TSA.
   
Distributions attributable to salary reduction contributions made
after Dec. 31, 1988, plus the earnings on them, or to transfers or
rollovers of such amounts from other contracts, may be made from
the TSA only if the owner has attained age 59-1/2, has become
disabled as defined in the Code, has separated from the service of
the employer that purchased the Certificate or has died. 
Additionally, if the owner should encounter a financial hardship
(within the meaning of the Code), he or she may receive a
distribution of all certificate values attributable to salary
reduction contributions made after Dec. 31, 1988, but not of the
earnings on them.  These restrictions do not apply to the Dec. 31,
1988 value or to transfers or exchanges of contract values within
the Certificate or to another registered variable annuity contract
or investment vehicle available through the employer.
    
Even though a distribution may be permitted under these rules
(e.g., for hardship or after separation from service), it may
nonetheless be subject to a 10 percent IRS penalty tax (in addition
to income tax) as a premature distribution and to 20 percent income
tax withholding.  See the section called "Federal Tax Information."

In addition, for certain types of contributions under a Section
403(b) annuity to be excluded from taxable income, the employer
must comply with certain nondiscrimination requirements.  You
should consult your employer to determine whether the
nondiscrimination rules apply to you.

Systematic Withdrawals - IDS Life of New York allows you to
establish systematic withdrawals of certificate values through a
one-time written request or other method acceptable to IDS Life of
New York.  Amounts of up to 10 percent of the certificate value at
the beginning of the certificate year may be withdrawn.  The
minimum systematic withdrawal amount from the certificate is $100,
and such withdrawals can be made on a monthly, quarterly,
semiannual or annual basis.  You may designate systematic
withdrawals be made from the Annuity in one of the following ways: 

o withdrawing a specific total dollar amount prorated from all
subaccounts and/or the Fixed Account in which you have a balance
(if no other choice is made, amounts will be withdrawn under this
method);

o withdrawing a specific total dollar amount and also specifying
which percentage of that total amount will be withdrawn from all
subaccounts and/or the Fixed Account in which you have a balance;
or

o withdrawing only the interest credited to the Fixed Account over
the systematic withdrawal period.

The minimum certificate value required to begin systematic
withdrawals is $5,000.  You may start or stop this service at any
time, but must give IDS Life of New York 30 days' notice to change
any systematic withdrawal instructions that are currently in place. 
IDS Life of New York will not deduct surrender charges for<PAGE>
PAGE 28
first-year systematic withdrawals of amounts up to 10 percent of
the initial purchase payment.
   
Systematic withdrawals may result in income taxes, withholding
taxes and penalty taxes being applied to all or a portion of the
amount withdrawn.  You should consult your tax advisor regarding
the tax consequences of systematic withdrawals.
    
Partial Surrenders -- The minimum amount you may surrender is $500. 
You cannot make a partial surrender if it would reduce the value of
your investment in a subaccount or in the Fixed Account to less
than $500 unless the value of your investment in a subaccount or in
the Fixed Account is fully withdrawn.

If you have a balance in more than one subaccount and/or in the
Fixed Account and request a partial surrender, IDS Life of New York
will withdraw money from all the subaccounts and/or the Fixed
Account in the same proportion as your value in each subaccount or
in the Fixed Account bears to your total certificate value, unless
you request otherwise.

A partial surrender request not exceeding $40,000 may be made by
telephone.  IDS Life of New York has the authority to honor any
telephone requests believed to be authentic and will use reasonable
procedures to confirm that they are.  This includes asking
identifying questions and tape recording calls.  As long as the
procedures are followed, neither IDS Life of New York nor its
affiliates will be liable for any loss resulting from fraudulent
requests.  At times when the volume of telephone requests is
unusually high, IDS Life of New York will take special measures to
ensure that your call is answered as promptly as possible.  A
telephone surrender request will not be allowed within 30 days of a
phoned-in address change.

You may request that telephone withdrawals not be authorized from
your account by writing IDS Life of New York.

Total Surrenders -- IDS Life of New York will compute the value of
your Certificate at the close of business, currently the same as
the close of the NYSE, after receipt of your request for a complete
surrender.  IDS Life of New York may ask you to return the
Certificate.

Receiving Payment -- Payment will be mailed within seven days after
IDS Life of New York receives your request.  However, IDS Life of
New York may postpone payment if:

o the surrender value includes a purchase payment check that has
not cleared; 

o the NYSE is closed, except for normal holiday and weekend
closings;

o trading on the NYSE is restricted according to the rules of the
SEC;

<PAGE>
PAGE 29
   
o an emergency, as defined by the rules of the SEC, makes it
impracticable for the Portfolios and Funds to sell securities or to
value the Portfolios' or Funds' net assets; or
    
o the SEC permits a delay in payment for the protection of owners.

Payment in Case of Death before Retirement Payments Begin

Prior to the retirement date, if you or the annuitant die before
the initial fifth certificate anniversary, IDS Life of New York
will pay the beneficiary the greater of:

1) the certificate value; or

2) the amount of purchase payments (minus any surrenders).

On or after the initial fifth certificate anniversary, and each
subsequent fifth certificate anniversary, IDS Life of New York will
pay the beneficiary the greater of:

1) the certificate value; or

2) a minimum guaranteed death benefit which equals:   

   a) the death benefit calculated as of the previous fifth
      certificate anniversary; plus

   b) any purchase payments made since the previous fifth
      certificate anniversary; minus

   c) any surrenders since the previous fifth certificate
      anniversary.

Certificate value is determined as of the date IDS Life of New York
receives proof of death.

If Your Spouse is Sole Beneficiary -- If you, as owner of the
Certificate, die before the retirement date and your spouse is the
only beneficiary of the Certificate, your spouse may keep the
Certificate as owner and annuitant.  To do this, within 60 days
after IDS Life of New York receives proof of death, it must receive
written instructions from your spouse to keep the Certificate in
force.
   
Section 401(k) Plans, TSAs, Custodial and Trusteed Plans, and IRAs
- -- If you buy the Certificate in connection with a Section 401(k)
plan, custodial or trusteed plan or as an IRA or TSA and you die
before reaching age 70-1/2 and your spouse is the only beneficiary,
your spouse may keep the Certificate in force until the date on
which you would have reached age 70-1/2 or such other date as 
provided in the Code.  To do this, within 60 days after IDS Life of
New York receives proof of death, it must receive written
instructions from your spouse to keep the Certificate in force.
    <PAGE>
PAGE 30
Paying the Beneficiary -- Unless you have given IDS Life of New
York other written instructions,  IDS Life of New York will pay the
beneficiary in a single lump sum payment.  The beneficiary may
elect to receive payment any time within 5 years after the date of
death.  Payments made from a Certificate purchased to fund certain
qualified plans to a surviving spouse instead of being directly
rolled over into an IRA may be subject to 20 percent income tax
withholding.  See the section called "Federal Tax Information." 
IDS Life of New York may make payments under any retirement payment
plan available under this Annuity if:

o the beneficiary asks IDS Life of New York in writing within 60
days after IDS Life of New York receives proof of death;

o payments begin no later than one year after death; and

o the payment period does not extend beyond the beneficiary's life
or life expectancy in accordance with applicable provisions of the
Code.

When paying the certificate value to the beneficiary, IDS Life of
New York will determine the Certificate's value at the next close
of the NYSE after IDS Life of New York's death claim requirements
are fulfilled.  Interest, if any, is paid at a rate no less than
that required by applicable law.  IDS Life of New York will mail
payment to the beneficiary within seven days after all death claim
requirements are fulfilled.

Settlement Value of Your Certificate
   
The amount available on the retirement date to provide payments
under a retirement payment plan is the current value of your
investment, called the certificate value.  Because Portfolio or
Fund investments (other than those in the Money Market Portfolio)
fluctuate in value each day, there can be no guarantee that the
certificate value will exceed, or even equal, the amount of your 
purchase payments.  You will receive quarterly statements showing
your certificate value and any other information required by
applicable law at least annually.
    
On your retirement date, the certificate value is applied to IDS
Life of New York's current fixed table of settlement rates, which
will be at least as favorable as that contained in the Certificate.

IDS Life of New York then calculates lifetime annuity payments
according to the retirement payment plan you choose.
A unisex table of settlement rates will apply, except when the
Certificate is used to fund an IRA or a non-qualified plan.  

Payout Options at Retirement

As the owner of the Certificate, you have the right to decide how
retirement payments are to be made.  You may select one of the
retirement payment plans outlined below, or you and IDS Life of New
York may mutually agree on other payment arrangements.  Annuity <PAGE>
PAGE 31
payments will be made on a fixed basis.  A fixed annuity is one
with payments that are guaranteed by IDS Life of New York as to
dollar amount.  Fixed annuity payments after the first payment will
never be more or less than the first payment.

Retirement Payment Plans -- You may choose any one of these payment
plans by giving IDS Life of New York written instructions at least
30 days before the retirement date:

o Plan A - Life Annuity - No Refund -- Monthly payments are made
until the annuitant's death.  Payments end with the last monthly
payment before the annuitant's death; no further payments will be
made.  You should understand that if the annuitant dies after only
the first monthly payment, no further payments will be made.

o Plan B - Life Annuity with 5, 10 or 15 Years Certain -- Monthly
payments are made until the annuitant's death.  However, payments
are guaranteed for 5, 10 or 15 years.  If the annuitant dies before
all guaranteed payments have been made, IDS Life of New York will
continue making those guaranteed payments to you, if living; if
not, to your beneficiary; or, if no beneficiary is named, to your
estate.

o Plan C - Life Annuity - Installment Refund -- Monthly payments
are made until the annuitant's death.  However, payments are
guaranteed to continue for at least the number of months determined
by dividing the certificate value at the time of retirement by the
amount of the monthly payment.  If the annuitant dies before all
guaranteed payments have been made, IDS Life of New York will
continue making those guaranteed payments to you, if living; if
not, to your beneficiary; or, if no beneficiary is named, to your
estate.

o Plan D - Joint and Last Survivor Life Annuity - No Refund --
Monthly payments are made while both the annuitant and a joint
annuitant are living.  If either annuitant dies, monthly payments 
continue at the full amount until the death of the surviving
annuitant.  Payments end with the death of the second annuitant,
and no further payments will be made.  You should understand that
if both the annuitant and the joint annuitant die after only the
first monthly payment, no further payments will be made.

o Plan E - Period Certain Annuity -- Monthly payments are made for
a period of years.  The period of years may be no less than 10
years and no more than 30 years.  Even if the annuitant lives
beyond the period of years selected, no further payments will be
made.  However, if the annuitant dies before the end of the period 
selected, IDS Life of New York will continue making monthly
payments to you, if living; if not, to your beneficiary; or, if no
beneficiary is named, to your estate.

Restrictions for Some Qualified Plans -- If your Certificate was
purchased in connection with a Section 401(k) plan, custodial or <PAGE>
PAGE 32
trusteed plan, or as a TSA or an IRA, you must select a payment
plan (in accordance with the applicable provisions of the Code)
that provides for payments:

o over the life of the annuitant;

o over the joint lives of the annuitant and beneficiary;

o for a period not exceeding the life expectancy of the annuitant;
or

o for a period not exceeding the joint life expectancies of the
annuitant and beneficiary.

If IDS Life of New York Does Not Receive Instructions -- You must
give IDS Life of New York written instructions for paying
retirement benefits at least 30 days before the retirement date. 
If you do not, IDS Life of New York will make payments under Plan
B, with 120 monthly payments guaranteed.

If Monthly Payments Would be Less than $50 -- IDS Life of New York
will calculate your certificate value at the retirement date.  If
the calculations show that monthly payments would be less than $50,
IDS Life of New York reserves the right to change the frequency of
the retirement payments or to pay the certificate value in one lump
sum.  

Death After Retirement Payments Begin -- If you or the annuitant
die after retirement payments begin, any amount payable, as
provided in the retirement payment plan in effect, will be
continued to the beneficiary, if living; if not, the owner, if
living; if not, the owner's estate.

Changing Ownership

You may change ownership of your Certificate at any time by filing
a change of ownership form with IDS Life of New York at its home
office.  No change of ownership will be binding upon IDS Life of 
New York until the change is received and recorded.  IDS Life of
New York takes no responsibility for the validity of the change.

If you have a qualified plan, the Certificate may not be sold,
assigned, transferred, discounted or pledged as collateral for a
loan or as security for the performance of an obligation or for any
other purpose to any person other than IDS Life of New York. 
However, if the owner is a trust or custodian, or an employer
acting in a similar capacity, ownership of a Certificate may be
transferred to the annuitant.

The value of any part of a non-qualified Certificate assigned or
pledged is taxed like a cash withdrawal to the extent allocable to
investment in the Certificate.

Transfer of a non-qualified Certificate to another person without
adequate consideration is considered a gift and the transfer may be
considered a surrender of the Certificate for federal income tax <PAGE>
PAGE 33
   
purposes.  The income on the Certificate will be taxed to the
transferor (original owner), who may be subject to a 10 percent IRS
penalty tax for early withdrawal.  The transferee's (new owner's)
investment in the Certificate will be the value of the Certificate
at the time of the transfer.  Consult with your tax advisor before
taking any action.
    
Federal Tax Information
   
Under current law, there is no liability for federal income tax on
any increase in the Certificate's value until payments are made,
except as discussed above in "Changing Ownership." However, since
federal tax consequences cannot always be anticipated, you should
consult a tax advisor if you have any questions about the taxation
of your Certificate.
    
You are not taxed on your investment in the Certificate.  Your
investment generally includes purchase payments made into the
Certificate with after-tax dollars.  If the investment in the
Certificate was made by you or on your behalf with pre-tax dollars
as part of a qualified retirement plan, such amounts are not
considered to be part of your investment in the Certificate and
will be taxed when paid to you.

If you surrender part or all of your Certificate before the date on
which retirement payments begin, you will be taxed on the payments
that you receive to the extent that the value of your Certificate
exceeds your investment.  In addition, you may have to pay a 10
percent IRS penalty tax for early withdrawal and, for surrenders
from Certificates purchased to fund qualified plans and TSAs, 20
percent income tax withholding may be imposed.

If payments begin under a non-qualified Certificate, a portion of
each payment will be subject to tax and a portion of each payment
will be considered a return of part of your investment in the
Certificate and will not be taxed.  All amounts received after your
investment is recovered will be subject to tax.  If payments begin
under a qualified Certificate, for example an IRA, TSA, or Section 
401(k) plan, all of the payments generally will be subject to
taxation except to the extent that the contributions were made with
after-tax dollars.

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

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

The income earned on a Certificate held by such entities as
corporations, partnerships or trusts generally will be treated as
ordinary income received during that year.
<PAGE>
PAGE 34
You may have to pay a 10 percent IRS penalty tax on any amount
includable in your ordinary income.  This penalty will not apply to
any amount received:

o after you reach age 59-1/2; 

o because of your death;

o because you become disabled (as defined in the Code);

o if the distribution is part of a series of substantially equal
periodic payments made at least annually, over your life or life
expectancy (or joint lives or life expectancies of you and your
designated beneficiary); or

o if it is allocable to an investment before Aug. 14, 1982 (except
for Certificates in qualified plans).

These are the major exceptions to the 10 percent IRS penalty tax. 
Additional exceptions may apply depending upon whether your
Certificate is qualified.  For qualified Certificates, other
penalties apply if you surrender a Certificate before the plan
specifies that payments can be made under the plan.

In general if you receive all or a portion of the value of a
Certificate you purchased to fund a qualified plan such as a 401(k)
plan or TSA (but not an IRA), mandatory 20 percent income tax
withholding will be imposed at the time the payment is made.  In
addition, federal income tax and the 10 percent IRS penalty tax for
early withdrawals may apply to amounts properly includable in
income.  This mandatory 20 percent income tax withholding will not
be imposed if:

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

o the payment is one of a series of substantially equal periodic
payments made at least annually, over your life or life expectancy
(or joint lives or life expectancies of you and your designated
beneficiary) or made over a period of 10 years or more; or

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

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

You will receive a tax statement for any year in which you receive
a taxable distribution from your Certificate.

<PAGE>
PAGE 35
   
Our discussion of federal tax laws is based on our understanding of
these laws as they are currently interpreted.  Either federal tax
laws or current interpretations of them may change.  You are urged
to consult your tax advisor regarding your specific circumstances.  
     
Additional Information about the Annuity and Certificates 

Accumulation Units

When your purchase payments are allocated to the subaccount(s) you
have chosen, they will be converted into accumulation units.  The
number of accumulation units to be credited to your Certificate is
determined by dividing the purchase payment by the accumulation
unit value.  

Accumulation Unit Value -- The accumulation unit value for each
subaccount was originally set at $1.  IDS Life of New York
determines the current accumulation unit value by taking the last
accumulation unit value for that subaccount and multiplying it by
the current net investment factor.

Net Investment Factor -- The net investment factor is determined
by:
   
o adding the Portfolio's or Fund's net asset value per share and
the per share amount of any current dividend or capital gain
distribution made by the Portfolio or Fund and held in the
subaccount;
    
o dividing that sum by the last net asset value per share; and

o subtracting the percentage factor representing the mortality and
expense risk fee and Variable Account administrative charge from
the result.

Because the net investment factor may be greater or less than one,
the accumulation unit value may increase or decrease.  You bear
this investment risk.
   
Distribution of the contracts

Smith Barney Inc. is the principal underwriter of the certificate. 
IDS Life of New York pays total commissions of up to 7.0% of the
total purchase payments received on the contracts.   
    
<PAGE>
PAGE 36
   
About the Portfolios and Funds
       
Voting Rights -- As the Certificate owner, you have voting rights
in the Smith Barney Series Fund and the Portfolios and in the
Funds, the shares of which are held by the subaccounts in which you
have invested.  IDS Life of New York will vote the shares of each
Portfolio and Funds in which you have a beneficial interest
according to the instructions received from you.  The number of
votes you have is determined by applying your percentage interest
in the subaccount to the total number of votes allowed to the
subaccount.
       
IDS Life of New York calculates votes separately for each
subaccount, and will do this not more than 60 days before a meeting
of beneficial owners of the Portfolios and Funds.  Owners with an
interest in the matter or matters being considered will receive
notice of these meetings, proxy materials and a statement of the
number of votes to which they are entitled.
       
If you do not give IDS Life of New York voting instructions, it
will vote your shares in the same proportion as the votes for which
it has received instructions.  IDS Life of New York also will vote
the shares for which it has voting rights in the same proportion as
the votes for which it has received instructions.  See the
accompanying prospectuses for a detailed description of voting
rights in the Portfolios and Funds.
       
Substitution of Investments -- If shares of any Portfolio or Funds
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 may be substituted for
Portfolio or Fund shares held in the subaccounts.  If deemed by IDS
Life of New York to be in the best interest of persons having
voting rights under the Annuity, the Variable Account may be
operated as a management company under the 1940 Act 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, without the consent or approval of the
owners, may amend the Annuity and related Certificates and take
whatever action is necessary and appropriate.  
    
However, no such substitution or change will be made without any
necessary approval of the SEC and state insurance department.  IDS
Life of New York will notify owners of any substitution or change.

Information on the Fixed Account of the Annuity
   
In addition to the thirteen subaccounts of the Variable Account
described in this prospectus, the Annuity has a Fixed Account
available for allocation of purchase payments.  Generally, the
information in the section called "Using the Annuity and
Certificate" applies in a like manner to the Fixed Account. 
However, there are some differences.
    
<PAGE>
PAGE 37
The Fixed Account operates like a traditional annuity.  Fixed
annuity cash values increase based on interest rates that may
change from time to time but are guaranteed by IDS Life of New
York.  Interest is credited and compounded daily to yield an
effective annual interest rate.  The minimum guaranteed interest 
rate is 4 percent.  Purchase payments and transfers to the Fixed
Account become part of the general account of IDS Life of New York. 
In contrast, purchase payments and transfers to the subaccounts of
the Variable Account go into a segregated asset account; they are
not mingled with IDS Life of New York's main portfolio of
investments that support fixed annuity obligations.  The gains
achieved or losses suffered by the segregated asset account have no
effect on the Fixed Account.

The Annuity allows you to transfer certificate values between the
Fixed Account and the subaccounts, but such transfers are
restricted as follows:

1. You may transfer certificate values from the Fixed Account to
the subaccount(s) or from the subaccount(s) to the Fixed Account up
to six times per certificate year, subject to restrictions #2 and
#3 below.

2. If a transfer is made from the Fixed Account to the
subaccount(s), no subsequent transfer from any subaccount back to
the Fixed Account may be made for six months from the last transfer
date from the Fixed Account.

3. Except for automated transfers of certificate values, transfers
must be for at least $500 or your entire balance in the Fixed
Account, if less.

IDS Life of New York may, in its sole discretion and subject to
regulatory approval, suspend or modify these transfer privileges at
any time.

The Annuity allows you to make automated transfers of certificate
values between the Fixed Account and the subaccounts, but such
transfers may not exceed an amount that, if continued, would
deplete the Fixed Account within 12 months.  The minimum automated
transfer amount is $100.  Such transfers may be made on a monthly,
quarterly, semiannual or annual basis.  The limit on transfers 
between the Fixed Account and subaccounts to six times per year may
be waived if the automated transfer of certificate values service 
is in effect.  You may start or stop this service at any time, but
you must give IDS Life of New York 30 days' notice to change any
automated transfer instructions that are currently in place. 
Automated transfers are subject to all of the other Annuity
provisions and terms.

If you make any type of transfer from the Fixed Account, you may
not transfer certificate values from any subaccount back to the
Fixed Account for six months from the last transfer date from the
Fixed Account.

<PAGE>
PAGE 38
The mortality and expense risk charge and the Variable Account
administrative charge do not apply to values allocated to the Fixed
Account.  However, the other charges described in this prospectus
do apply to the Fixed Account.

Because of exemptive and exclusionary provisions, interests in IDS
Life of New York's general account have not been registered under
the Securities Act of 1933, as amended (1933 Act), nor is the
general account registered as an investment company under the 1940
Act.  Accordingly, neither the general account of IDS Life of New
York nor any interests therein are generally subject to the
provisions of the 1933 or 1940 Acts, and IDS Life of New York has
been advised that the staff of the SEC has not reviewed the
disclosures in this prospectus that relate to the Fixed Account. 
Disclosures regarding the Fixed Account of the Annuity and the
general account of IDS Life of New York, however, may be subject to
certain generally applicable provisions of the federal securities
laws relating to the accuracy and completeness of statements made
in the prospectuses. 

Table of Contents of the SAI 
   
                                                               Page 

Performance Information..........................................3

Rating Agencies..................................................5

Principal Underwriter............................................5

Independent Auditors.............................................5

Mortality and Expense Risk Fee...................................5

Prospectus.......................................................6
    
Financial Statements
     IDS Life of New York Account SBS
     IDS Life Insurance Company of New York
___________________________________________________________________
If you would like to receive a copy of the SAI for:
   
   Symphony Annuity
   (IDS Life of New York Account SBS)
    
please return this request to:
       
   IDS Life Insurance Company of New York 
   P.O. Box 5144 
   Albany, New York 12205

   Your name___________________________________________

   Address_____________________________________________

   City_________________________ State______ Zip_______
<PAGE>
PAGE 39



















                  STATEMENT OF ADDITIONAL INFORMATION

                                  for

                           SYMPHONY ANNUITY

                   IDS LIFE OF NEW YORK ACCOUNT SBS
   
                              May 1, 1995
    

IDS Life of New York Account SBS is a separate account established
and maintained by IDS Life Insurance Company of New York (IDS Life
of New York).
   
This Statement of Additional Information (SAI), dated May 1, 1995,
is not a prospectus.  It should be read together with the Account's
prospectus, dated May 1, 1995, which may be obtained from your
Smith Barney Financial Consultant, or by writing or calling IDS
Life of New York Annuity Service at the address or telephone number
below.
    

   
IDS Life Insurance Company of New York
20 Madison Avenue Extension
Albany, NY  12203
(518) 869-8613
    <PAGE>
PAGE 40
                           TABLE OF CONTENTS
   
Performance Information........................................p. 3

Rating Agencies................................................p. 5

Principal Underwriter..........................................p. 5

Independent Auditors...........................................p. 5
 
Mortality and Expense Risk Fee.................................p. 5

Prospectus.....................................................p. 6

Financial Statements
 
     - IDS Life of New York Account SBS......................p. 7
     - IDS Life Insurance Company of New York................p.15
    <PAGE>
PAGE 41
PERFORMANCE INFORMATION 
   
Calculation of Yield for the New York Money Market Subaccount 
       
Simple yield for the New York Money Market subaccount will be based
on the: (a) change in the value of a hypothetical investment
(exclusive of capital changes) at the beginning of a seven-day
period for which yield is to be quoted; (b) subtracting a pro rata
share of subaccount expenses accrued over the seven-day period; (c)
dividing the difference by the value of the subaccount at the
beginning of the period to obtain the base period return; and (d)
annualizing the results (i.e., multiplying the base period return
by 365/7).  Calculation of effective yield begins with the same
base period return used in the calculation of yield, which is then
annualized to reflect compounding according to the following
formula:
     
                                                365/7
      Effective Yield =[(Base Period Return + 1)      ]-1
   
On Dec. 31, 1994, the Account's simple yield was 2.14% and its
effective yield was 2.16%.
       
Calculation of Yield for the Non Money Market Subaccounts
       
For a subaccount other than the Money Market subaccount, quotations
of yield will be based on all investment income earned during a
particular 30-day period, less expenses accrued during the period
(net investment income) and will be computed by dividing net
investment income per accumulation unit by the value of an
accumulation unit on the last day of the period, according to the
following formula:
    
                      YIELD = 2 [(a-b + 1)6 - 1]
                             cd

where:    a =  dividends and investment income earned during the
               period.
          b =  expenses accrued for the period (net of
               reimbursements).
          c =  the average daily number of accumulation units
               outstanding during the period that were entitled
               to receive dividends.
          d =  the maximum offering price per accumulation unit
               on the last day of the period.
   
Yield on the subaccount is earned from the increase in the net
asset value of shares of the portfolio or fund in which the
subaccount invests and from dividends declared and paid by the
fund, which are automatically invested in shares of the portfolio
or fund.
    <PAGE>
PAGE 42
Calculation of Average Annual Total Return 
   
Quotations of average annual total return for any subaccount will
be expressed in terms of the average annual compounded rate of
return of a hypothetical investment in the certificate over a
period of one, five and 10 years (or, if less, up to the life of
the subaccount), calculated according to the following formula:
    
                 P(1+T)n = ERV

where:  P =    a hypothetical initial payment of $1,000.
        T =    average annual total return.
        n =    number of years.
      ERV =    Ending Redeemable Value of a hypothetical $1,000
               payment made at the beginning of the one-, five or
               ten-year (or other) period at the end of the one-,
               five- or ten-year (or other) period (or fractional
               portion thereof).
   
Subaccount total return figures reflect the deduction of the
certificate administrative charge, Variable Account administrative
charge and mortality and expense risk fee.  Performance figures
will be shown with the deduction of the applicable surrender
charge; in addition, performance figures may be shown without the
deduction of a surrender charge.  The Securities and Exchange
Commission (SEC) requires that an assumption be made that the owner
surrenders the entire certificate at the end of the one, five and
ten year periods (or, if less, up to the life of the subaccount)
for which performance is required to be calculated.
    
Aggregate Total Return
   
Aggregate total return represents the cumulative change in the
value of an investment over a specific period of time (reflecting
change in a subaccount's accumulation unit value) and is computed
by the following formula:
    
ERV - P
P

where:  P  =   a hypothetical initial payment of $1,000.
      ERV  =   Ending Redeemable Value of a hypothetical $1,000
               payment made at the beginning of the one-, five-, or
               ten-year (or other) period at the end of the one-,
               five, or ten-year (or other) period (or fractional
               portion thereof).

Performance of the subaccounts may be quoted or compared to
rankings, yields, or returns as published or prepared by
independent rating or statistical services or publishers or
publications such as Barron's, Business Week, Forbes, Fortune,
Institutional Investor, Investor's Daily, Kiplinger's Personal
Finance, Money, Morningstar Mutual Fund Values, Mutual Fund
Forecaster, The New York Times, Stranger's Investment Advisor, USA
Today, U.S. News & World Report and The Wall Street Journal.
<PAGE>
PAGE 43
RATING AGENCIES
   
The following chart reflects the ratings given to IDS Life
Insurance Company of New York by independent rating agencies. 
These agencies evaluate the financial soundness and claims-paying
ability of insurance companies based on a number of different
factors.  This information does not relate to the management or
performance of the variable subaccounts. This information relates 
only to the fixed account and reflects IDS Life of New York's
ability to make annuity payouts and to pay death benefits and other
distributions from the certificate.
    
Rating agency             Rating

A.M. Best               A+
                    (Superior)

Duff & Phelps          AAA

Moody's                Aa2
   
PRINCIPAL UNDERWRITER

The principal underwriter for the Account is Smith Barney Inc.,
which offers the variable annuity on a continuous basis.
       
Surrender charges received by IDS Life of New York for 1994, 1993
and 1992 aggregated $269,275, $151,536, and $136,471, respectively. 
       
Commissions paid by IDS Life of New York for 1994, 1993 and 1992
aggregated $1,130,352, $1,244,668 and $631,691, respectively.  The
surrender charges were applied toward payment of commissions.
    
INDEPENDENT AUDITORS
   
The financial statements of IDS Life of New York Account SBS
including the statements of net assets as of Dec. 31, 1994, and the
related statements of operations for the year then ended and the
related statements of changes in net assets for the period from
March 15, 1993 (commencement of operations) to Dec. 31, 1993 and
for the year ended Dec. 31, 1994, and the financial statements of
IDS Life Insurance Company of New York (a wholly owned subsidiary
of IDS Life Insurance Company) as of Dec. 31, 1994 and for each of
the three years in the period then ended, appearing in this SAI,
have been audited by Ernst & Young LLP, independent auditors, as
stated in their reports appearing herein. 
    
MORTALITY AND EXPENSE RISK FEE

IDS Life of New York has represented to the SEC that:

IDS Life of New York has reviewed publicly available information
regarding products of other companies.  Based upon this review, IDS
Life of New York has concluded that the mortality and expense risk 
<PAGE>
PAGE 44
fee is within the range of charges determined by industry practice
and that the level of the mortality and expense risk charge is
reasonable in relation to the risks assumed by IDS Life of New York
under the Annuities.  IDS Life of New York will maintain at its
principal office, and make available on request of the SEC or its
staff, a memorandum setting forth in detail the variable products
analyzed and the methodology, and results of, its comparative
review.

IDS Life of New York has concluded that there is a reasonable
likelihood that the proposed distribution financing arrangements
made with respect to the Annuities will benefit the Variable
Account and investors in the Annuities.  The basis for such
conclusion is set forth in a memorandum which will be made
available to the Commission or its staff on request.

PROSPECTUS
   
The prospectus dated May 1, 1995, is hereby incorporated in this
SAI by reference.
    <PAGE>
PAGE 45
The financial statements shown below are those of the insurance
company and not those of the Funds or the Accounts.  They are
included in the prospectus for the purpose of informing investors
as to the financial condition of the insurance company and its
ability to carry out its obligations under the variable annuity
contracts.

<TABLE>
<CAPTION>

IDS Life of New York Account SBS
________________________________________________________________________________________________________________________
Statements of Net Assets                                                                                   Dec. 31, 1994
                                                                                                                       
                                               __________________Segregated Asset Subaccounts___________________________
Assets                                              BMO         BIH         BDS         BEM         BEX         BGI    
________________________________________________________________________________________________________________________  
<S>                                             <C>         <C>         <C>         <C>         <C>         <C> 
Investments in shares of mutual fund
 portfolios, at market value:
Smith Barney Series Fund Money Market Portfolio - 
 554,128 shares at net asset value of
 $1.00 per share (cost $554,128)                $  554,128  $         - $         - $         - $         - $         -
Smith Barney Series Fund Intermediate High Grade
 Portfolio - 74,846 shares at net asset value of
 $9.66 per share (cost $780,467)                         -      723,014           -           -           -           -
Smith Barney Series Fund Diversified Strategic Income
 Portfolio - 318,057 shares at net asset value
 of $9.18 per share (cost $3,154,508)                    -            -   2,919,767            -           -           -
Smith Barney Series Fund Equity Income Portfolio - 
 176,868 shares at net asset value of $9.86
 per share (cost $1,988,546)                             -            -           -   1,743,914           -           -
Smith Barney Series Fund Equity Index Portfolio - 
 111,812 shares at net asset value of $11.69
 per share (cost $1,281,698)                             -            -           -           -   1,307,085           -
Smith Barney Series Fund Growth & Income Portfolio - 
 169,860 shares at net asset value of $10.74
 per share (cost $1,878,964)                             -            -           -           -           -   1,824,301
Smith Barney Series Fund Appreciation Portfolio - 
 285,048 shares at net asset value of $11.54
 per share (cost $3,272,896)                             -            -           -           -           -           -
Smith Barney Series Fund Total Return Portfolio - 
 98,580 shares at net asset value of $10.78
 per share (cost $1,057,339)                             -            -           -           -           -           -
Smith Barney Series Fund Emerging Growth Portfolio - 
 69,585 shares at net asset value of $9.63,
 per share (cost $687,906)                               -            -           -           -           -           -
Smith Barney Series Fund International Equity Portfolio - 
 184,448 shares at net asset value of $9.21
 per share (cost $1,805,902)                             -            -           -           -           -           -
IDS Life Capital Resource Fund -
  -0- shares at net asset value of $22.78
  per share (cost $-0-)                                  -            -           -           -           -           -
IDS Life Special Income Fund, Inc -
  -0-  shares at net asset value of $10.63
  per share (cost $-0-)                                  -            -           -           -           -           -
IDS Life Managed Fund, Inc. -
  -0- shares at net asset value of $12.97
  per share (cost $-0-)                                  -            -           -           -           -           -
                                                   554,128      723,014   2,919,767   1,743,914   1,307,085   1,824,301
_______________________________________________________________________________________________________________________
Receivable from mutual fund portfolios
for share redemptions                                    -            -           -           -          23           7
_______________________________________________________________________________________________________________________
Total assets                                       554,128      723,014   2,919,767   1,743,914   1,307,108   1,824,308
_______________________________________________________________________________________________________________________
/TABLE
<PAGE>
PAGE 46
<TABLE><CAPTION>
IDS Life of New York Account SBS
________________________________________________________________________________________________
Statements of Net Assets                                          Dec. 31, 1994
                                                                              
                        __________________Segregated Asset Subaccounts____________________
Assets                                         BAP         BTR         BEG            BIE
______________________________________________________________________________________________
<S>                                          <C>         <C>         <C>          <C>
Investments in shares of mutual fund
portfolios, at market value:
Smith Barney Series Fund Money Market Portfolio -
 554,128 shares at net asset value of
 $1.00 per share (cost $554,128)             $         - $         - $         -  $         -
Smith Barney Series Fund Intermediate High Grade
 Portfolio - 74,846 shares at net asset value of
 $9.66 per share (cost $780,467)                       -           -           -            -
Smith Barney Series Fund Diversified Strategic Income
 Portfolio - 318,057 shares at net asset value
 of $9.18 per share (cost $3,154,508)                  -           -           -            -
Smith Barney Series Fund Equity Income Portfolio -
 176,868 shares at net asset value of $9.86
 per share (cost $1,988,546)                           -           -           -            -
Smith Barney Series Fund Equity Index Portfolio -
 111,812 shares at net asset value of $11.69
 per share (cost $1,281,698)                           -           -           -            -
Smith Barney Series Fund Growth & Income Portfolio -
 169,860 shares at net asset value of $10.74
 per share (cost $1,878,964)                           -           -           -            -
Smith Barney Series Fund Appreciation Portfolio -
 285,048 shares at net asset value of $11.54
 per share (cost $3,272,896)                   3,289,451           -           -            -
Smith Barney Series Fund Total Return Portfolio -
 98,580 shares at net asset value of $10.78
 per share (cost $1,057,339)                           -   1,062,722           -            -
Smith Barney Series Fund Emerging Growth Portfolio -
 69,585 shares at net asset value of $9.63
 per share (cost $687,906)                             -           -     670,101            -
Smith Barney Series Fund International Equity Portfolio -
 184,448 shares at net asset value of $9.21
 per share (cost $1,805,902)                           -           -           -    1,698,218
IDS Life Capital Resource Fund -
  -0- shares at net asset value of $22.78
  per share (cost $-0-)                                -           -           -            -
IDS Life Special Income Fund, Inc -
  -0- shares at net asset value of $10.63
  per share (cost $-0-)                                -           -           -            -
IDS Life Managed Fund, Inc. -
  -0- shares at net asset value of $12.97
  per share (cost $-0-)                                -           -           -            -
                                               3,289,451   1,062,722     670,101    1,698,218
Receivable from mutual fund portfolios
for share redemptions                                  7           8           -           74
Total assets                                   3,289,458   1,062,730     670,101    1,698,292
/TABLE
<PAGE>
PAGE 47
<TABLE><CAPTION>
Liabilities                                         BMO           BIH          BDS        BEM          BEX         BGI
________________________________________________________________________________________________________________________ 
<S>                                             <C>         <C>         <C>         <C>          <C>        <C>   
Payable to IDS Life of New York for:
Mortality and expense risk fee                         589          771       3,025       1,785       1,339       1,869 
Administrative charge                                  118          154         605         357         268         374
Contract terminations                                    -            -           -           -          23           7
Total liabilities                                      707          925       3,630       2,142       1,630       2,250
_______________________________________________________________________________________________________________________
Net assets applicable to contracts
in accumulation period                          $  553,421  $   722,089 $ 2,916,137 $ 1,741,772  $1,305,478 $ 1,822,058 
________________________________________________________________________________________________________________________
Accumulation units outstanding                     538,986      733,520   2,866,002   1,926,049   1,273,868   1,820,119 
________________________________________________________________________________________________________________________
Net asset value per accumulation unit           $     1.03  $      0.98 $      1.02 $      0.90  $     1.02 $      1.00 
________________________________________________________________________________________________________________________
See accompanying notes to financial statements.
</TABLE>
<TABLE><CAPTION>
Liabilities                                          BAP         BTR          BEG        BIE         
______________________________________________________________________________________________
<S>                                            <C>         <C>         <C>          <C>
Payable to IDS Life of New York for:
Mortality and expense risk fee                       3,374       1,064         696       1,764 
Administrative charge                                  675         213         139         353 
Contract terminations                                    7           8           -          74
______________________________________________________________________________________________
Total liabilities                                    4,056       1,285         835       2,191 
______________________________________________________________________________________________
Net assets applicable to contracts
in accumulation period                         $ 3,285,402 $ 1,061,445 $   669,266 $ 1,696,101
______________________________________________________________________________________________
Accumulation units outstanding                   3,267,489     975,070     706,221   1,872,309
Net asset value per accumulation unit          $      1.01 $      1.09 $      0.95 $      0.91
______________________________________________________________________________________________
See accompanying notes to financial statements.
/TABLE
<PAGE>
PAGE 48
<TABLE><CAPTION>
IDS Life of New York Account SBS
________________________________________________________________________________________________
Statements of Net Assets                                                                       Dec. 31, 1994
                                                                                                    Combined
                                        __________________Segregated Asset Subaccounts_________     Variable
Assets                                                         BCR         BSI         BMG           Account
<S>                                                        <C>         <C>           <C>          <C>     
Investments in shares of mutual fund
 portfolios, at market value:
Smith Barney Series Fund Money Market Portfolio -
 5548128 shares at net asset value of
 $1.00 per share (cost $554,128)                           $         - $         -   $        -   $    554,128
Smith Barney Series Fund Intermediate High Grade
 Portfolio - 74,846 shares at net asset value of
 $9.66 per share (cost $780,467)                                     -           -            -        723,014
Smith Barney Series Fund Diversified Strategic Income
 Portfolio - 318,057 shares at net asset value
 of $9.18 per share (cost $3,154,508)                                -           -            -      2,919,767
Smith Barney Series Fund Equity Income Portfolio -
 176,868 shares at net asset value of $9.86
 per share (cost $1,988,546)                                         -           -            -      1,743,914
Smith Barney Series Fund Equity Index Portfolio -
 111,812 shares at net asset value of $11.69
 per share (cost $1,281,698)                                         -           -            -      1,307,085
Smith Barney Series Fund Growth & Income Portfolio -
 169,860 shares at net asset value of $10.74
 per share (cost $1,878,964)                                         -           -            -      1,824,301
Smith Barney Series Fund Appreciation Portfolio -
 285,048 shares at net asset value of $11.54
 per share (cost $3,272,896)                                         -           -            -      3,289,451
Smith Barney Series Fund Total Return Portfolio -
 98,580 shares at net asset value of $10.78
 per share (cost $1,057,339)                                         -           -            -      1,062,722
Smith Barney Series Fund Emerging Growth Portfolio -
 69,585 shares at net asset value of $9.63
 per share (cost $687,906)                                           -           -            -        670,101
Smith Barney Series Fund International Equity Portfolio -
 184,448 shares at net asset value of $9.21
 per share (cost $1,805,902)                                         -           -            -      1,698,218
IDS Life Capital Resource Fund -
  -0- shares at net asset value of $22.78
  per share (cost $-0-)                                              -           -            -              -
IDS Life Special Income Fund, Inc -
  -0- shares at net asset value of $10.63
  per share (cost $-0-)                                              -           -            -              -
IDS Life Managed Fund, Inc. -
  -0- shares at net asset value of $12.97
  per share (cost $-0-)                                              -           -            -              -
                                                                     -           -            -     15,792,701
Receivable from mutual fund portfolios
for share redemptions                                                -           -            -            119
Total assets                                                         -           -            -     15,792,820
/TABLE
<PAGE>
PAGE 49
<TABLE><CAPTION>        
                                                                                                    Combined    
                                                                                                    Variable
Liabilities                                                    BCR         BSI          BMG         Account
____________________________________________________________________________________________________________
<S>                                                           <C>         <C>         <C>      <C>
Payable to IDS Life of New York for:
Mortality and expense risk fee                                       -           -           -       16,276 
Administrative charge                                                -           -           -        3,256 
Contract terminations                                                -           -           -          119
____________________________________________________________________________________________________________
Total liabilities                                                    -           -           -       19,651 
____________________________________________________________________________________________________________
Net assets applicable to contracts in accumulation
 period                                                       $      -    $      -    $      - $ 15,773,169
____________________________________________________________________________________________________________
Accumulation units outstanding                                       -           -           -
____________________________________________________________________________________________________________
Net asset value per accumulation unit                            $1.01       $0.99       $0.99
____________________________________________________________________________________________________________
See accompanying notes to financial statements.
</TABLE>
<PAGE>
PAGE 50
<TABLE>
<CAPTION>

IDS Life of New York Account SBS
_________________________________________________________________________________________________________________
Statements of Operations*                                                                Year ended Dec. 31, 1994
                                                                                                                
                              ____________________________Segregated Asset Subaccounts___________________________
                                  BMO         BIH        BDS         BEM         BEX         BGI           BAP
_________________________________________________________________________________________________________________
<S>                          <C>          <C>         <C>         <C>         <C>         <C>          <C>
Investment income (loss):
Dividend income from mutual
fund portfolios              $   17,729   $   53,738  $  182,721  $   81,553  $   32,216  $    41,407  $   31,451
_________________________________________________________________________________________________________________
Expenses:
Mortality and expense risk
fee (Note 3)                      6,083        9,726      35,362      20,408      15,894       21,478      36,739
Administrative charge (Note 4)    1,217        1,945       7,073       4,082       3,179        4,296       7,348
_________________________________________________________________________________________________________________
Total expenses                    7,300       11,671      42,435      24,490      19,073       25,774      44,087
_________________________________________________________________________________________________________________
Investment income
(loss) - net                     10,429       42,067     140,286       57,063     13,143       15,633     (12,636)
_________________________________________________________________________________________________________________

Realized and Unrealized Gain (Loss) on Investments - net
_________________________________________________________________________________________________________________
Realized gain (loss) on sales of investments in
 mutual fund portfolios:
Proceeds from sales             404,844      325,427     256,233      375,313     21,504      117,377     110,640
Cost of investments sold        404,844      337,370     270,567      409,981     21,192      118,863     108,945   
_________________________________________________________________________________________________________________
Net realized gain (loss)
on investments                        -      (11,943)    (14,334)     (34,668)       312       (1,486)      1,695
Net change in unrealized
appreciation or depreciation
of investments                        -      (62,133)   (256,290)    (219,196)   (22,569)     (98,648)    (71,529)
_________________________________________________________________________________________________________________
Net gain (loss) on
investments                           -      (74,076)   (270,624)   (253,864)   (22,257)    (100,134)    (69,834)
_________________________________________________________________________________________________________________
Net increase (decrease) in net assets
resulting from operations    $   10,429  $   (32,009)$  (130,338) $  (196,801)$   (9,114) $   (84,501)$   (82,470)
_________________________________________________________________________________________________________________
*Subaccounts BCR, BSI and BMG  had no activity in the period Nov. 28, 1994
(commencement of operations) to Dec. 31, 1994.
See accompanying notes to financial statements.
/TABLE
<PAGE>
PAGE 51
<TABLE><CAPTION>
IDS Life of New York Account SBS
___________________________________________________________________________
Statements of Operations*                          Year ended Dec. 31, 1994
                                                                   Combined
                             __Segregated Asset Subaccounts___     Variable
                               BTR        BEG         BIE           Account
___________________________________________________________________________
<S>                         <C>       <C>         <C>          <C>
Investment income (loss):
Dividend income from mutual 
fund portfolios             $ 20,476  $       47  $         -  $    461,338
___________________________________________________________________________
Expenses:
Mortality and expense
risk fee (Note 3)              8,872       6,109       16,676       177,347
Administrative charge
(Note 4)                       1,775       1,222        3,335        35,472
___________________________________________________________________________
Total expenses                10,647       7,331       20,011       212,819
___________________________________________________________________________
Investment income
(loss) - net                   9,829      (7,284)     (20,011)      248,519
___________________________________________________________________________


Realized and Unrealized Gain (Loss) on Investments - net
___________________________________________________________________________
Realized gain (loss) on sales
of investments in  mutual
fund portfolios:
Proceeds from sales           15,819     117,652      268,069     2,012,878
Cost of investments sold      15,376     122,103      281,905     2,091,146
___________________________________________________________________________
Net realized gain (loss)
on investments                   443      (4,451)     (13,836)      (78,268)
Net change in unrealized
appreciation or depreciation
of investments                 1,800     (23,047)    (109,492)     (861,104)
___________________________________________________________________________
Net gain (loss)
on investments                 2,243     (27,498)    (123,328)     (939,372)
___________________________________________________________________________
Net increase (decrease) in net assets
resulting from operations   $ 12,072  $  (34,782) $  (143,339)   $ (690,853)
___________________________________________________________________________
*Subaccounts BCR, BSI and BMG had no activity in the period Nov. 28, 1994
(commencement of operations) to Dec. 31, 1994.

See accompanying notes to financial statements.
/TABLE
<PAGE>
PAGE 52
<TABLE><CAPTION>
IDS Life of New York Account SBS
_____________________________________________________________________________________________________________________
Statements of Changes in Net Assets*                                                         Year ended Dec. 31, 1994
                                                                                                                              
                      ____________________________________Segregated Asset Subaccounts_____________________________
Operations                    BMO        BIH            BDS            BEM          BEX          BGI           BAP
_____________________________________________________________________________________________________________________
<S>                      <C>         <C>            <C>           <C>           <C>         <C>           <C>         
Investment income
(loss) - net             $   10,429  $    42,067    $   140,286   $    57,063   $   13,143  $    15,633   $   (12,636)
Net realized gain
(loss) on investments             -      (11,943)       (14,334)      (34,668)         312       (1,486)        1,695
Net change in unrealized
appreciation or
depreciation of
investments                       -      (62,133)      (256,290)     (219,196)     (22,569)     (98,648)      (71,529)
______________________________________________________________________________________________________________________
Net increase (decrease) in
net assets resulting
from operations              10,429      (32,009)      (130,338)     (196,801)      (9,114)     (84,501)      (82,470)
_____________________________________________________________________________________________________________________
Contract Transactions
_____________________________________________________________________________________________________________________
Variable annuity contract
purchase payments           436,859      297,011        936,978       504,669       130,647     412,899     1,098,452
Net transfers**            (346,270)    (287,489)        50,371      (130,572)       22,859     108,528       171,193
Contract charges               (260)         (92)        (1,098)         (752)         (373)       (672)       (1,378)
Contract terminations:
Surrender benefits                -      (10,660)      (115,745)      (23,741)       (2,533)     (6,312)      (48,296)
Death benefits                    -            -        (10,007)       (8,601)            -     (10,366)      (10,351)
_____________________________________________________________________________________________________________________
Increase (decrease) from
contract transactions        90,329       (1,230)       860,499       341,003       150,600     504,077     1,209,620
_____________________________________________________________________________________________________________________
Net assets at beginning
of period                   452,663      755,328      2,185,976     1,597,570     1,163,992   1,402,482     2,158,252
_____________________________________________________________________________________________________________________
Net assets at end
of period               $   553,421  $   722,089    $ 2,916,137   $ 1,741,772    $1,305,478 $ 1,822,058   $ 3,285,402
_____________________________________________________________________________________________________________________
Accumulation Unit Activity
_____________________________________________________________________________________________________________________
Units outstanding at
beginning of period         449,727      732,822      2,055,184     1,561,094     1,128,416   1,334,703     2,092,599
Contract purchase
payments                    430,435      298,002        891,708       525,661       126,063     399,701     1,067,763
Net transfers**            (340,920)    (286,350)        42,269      (124,111)       22,235     102,582       165,879
Contract terminations:
Surrender benefits             (256)     (10,954)      (113,352)      (26,884)       (2,846)     (6,872)      (48,703)
Death benefits                    -            -         (9,807)       (9,711)            -      (9,995)      (10,049)
_____________________________________________________________________________________________________________________
Units outstanding at
end of period               538,986      733,520      2,866,002     1,926,049     1,273,868   1,820,119     3,267,489
_____________________________________________________________________________________________________________________
*Subaccounts BCR, BSI and BMG had no activity in the period Nov. 28, 1994 (commencement of operations) to Dec. 31, 1994.
**Includes transfer activity from (to) other subaccounts and transfers from (to) IDS Life of New York's Fixed Account.
See accompanying notes to financial statements.
/TABLE
<PAGE>
PAGE 53
<TABLE><CAPTION>
IDS Life of New York Account SBS
_____________________________________________________________________________
Statements of Changes in Net Assets*                 Year ended Dec. 31, 1994
                                                                     Combined
                            ___Segregated Asset Subaccounts___       Variable
Operations                   BTR           BEG          BIE           Account
_____________________________________________________________________________
<S>                     <C>          <C>            <C>           <C>        
Investment income
(loss) - net            $     9,829  $    (7,284)   $   (20,011)  $   248,519
Net realized gain
(loss) on investments           443       (4,451)       (13,836)      (78,268)
Net change in unrealized
appreciation  or
depreciation of
investments                   1,800      (23,047)      (109,492)     (861,104)
_____________________________________________________________________________
Net increase (decrease)
in net assets resulting
from operations              12,072      (34,782)      (143,339)     (690,853)
_____________________________________________________________________________
Contract Transactions
_____________________________________________________________________________
Variable annuity contract
purchase payments           569,387      549,802      1,102,348     6,039,052
Net transfers**             270,576        7,635        431,426       298,257
Contract charges               (174)         (67)          (371)       (5,237)
Contract terminations:
Surrender benefits           (8,022)      (7,443)       (10,480)     (233,232)
Death benefits                    -            -              -       (39,325)
______________________________________________________________________________
Increase (decrease) from
contract transactions       831,767      549,927     1,522,923      6,059,515
______________________________________________________________________________
Net assets at beginning
of period                   217,606      154,121       316,517     10,404,507
______________________________________________________________________________
Net assets at end
of period               $ 1,061,445  $   669,266   $ 1,696,101    $15,773,169
______________________________________________________________________________
Accumulation Unit Activity
______________________________________________________________________________
Units outstanding at
beginning of period         211,477      148,221       315,305
Contract purchase
payments                    519,803      555,791     1,144,702
Net transfers**             251,307        9,856       423,647
Contract terminations:
Surrender benefits           (7,517)      (7,647)      (11,345)
Death benefits                    -            -             -
_______________________________________________________________
Units outstanding at
end of period               975,070      706,221     1,872,309
______________________________________________________________
*Subaccounts BCR, BSI and BMG had no activity in the period Nov. 28, 1994
(commencement of operations) to Dec. 31, 1994.
**Includes transfer activity from (to) other subaccounts and transfers
from (to) IDS Life of New York's Fixed Account.
See accompanying notes to financial statements.
/TABLE
<PAGE>
PAGE 54
<TABLE><CAPTION>
IDS Life of New York Account SBS
_______________________________________________________________________________________________________________________
Statements of Changes in Net Assets    For the period from March 15, 1993 (commencement of operations) to Dec. 31, 1993
                                                                                                                      
                      ____________________________________Segregated Asset Subaccounts_________________________________
Operations                                         BMO         BIH        BDS         BEM         BEX         BGI       
_______________________________________________________________________________________________________________________
<S>                                               <C>        <C>        <C>         <C>         <C>         <C> 
Investment income (loss) - net                   $  1,593      $9,693      $51,520     $20,345     ($7,069)     $9,989
Net realized gain (loss) on investments                 -         193           88        (263)        120       1,968
Net change in unrealized appreciation
 or depreciation of investments                         -       4,680       21,549     (25,436)     47,956      43,985
_______________________________________________________________________________________________________________________
Net increase (decrease) in net assets resulting
 from operations                                    1,593      14,566       73,157      (5,354)     41,007      55,942
_______________________________________________________________________________________________________________________
Contract Transactions
_______________________________________________________________________________________________________________________
Variable annuity contract purchase payments       562,833     753,883    2,109,639   1,525,286   1,111,973   1,351,318
Net transfers*                                   (108,550)           -       7,807     118,799      11,012       8,558
Contract terminations:
Surrender benefits                                 (3,213)    (13,121)      (4,627)    (41,161)          -     (13,336)
_______________________________________________________________________________________________________________________
Increase from contract transactions               451,070     740,762    2,112,819   1,602,924   1,122,985   1,346,540
_______________________________________________________________________________________________________________________
Net assets at beginning of period                       -           -            -           -           -          
- -_______________________________________________________________________________________________________________________
Net assets at end of period                      $452,663    $755,328   $2,185,976  $1,597,570  $1,163,992  $1,402,482
_______________________________________________________________________________________________________________________
Accumulation Unit Activity
_______________________________________________________________________________________________________________________
Units outstanding at beginning of period                -           -            -           -           -           -
Contract purchase payments                        560,849     745,580    2,052,140   1,487,108   1,117,604   1,339,170
Net transfers*                                   (107,925)          -        7,522     115,058      10,812       8,481
Contract terminations:
Surrender benefits                                 (3,197)    (12,758)      (4,478)    (41,072)          -     (12,948)
_______________________________________________________________________________________________________________________
Units outstanding at end of period                449,727     732,822    2,055,184   1,561,094   1,128,416   1,334,703
_______________________________________________________________________________________________________________________
*Includes transfer activity from (to) other subaccounts and transfers from (to) IDS Life of New York's Fixed Account.
**Commenced operations on Dec. 2, 1993.
See accompanying notes to financial statements.
</TABLE>
<PAGE>
PAGE 55
<TABLE><CAPTION>
IDS Life of New York Account SBS
____________________________________________________________________________________________________________
Statements of Changes in Net Assets   For the period from March 15, 1993 (commencement of operations) to Dec. 31, 1993
                                                                                                Combined
                     ________________Segregated Asset Subaccounts_____________________________ Variable
Operations                                     BAP         BTR**       BEG**       BIE**        Account
____________________________________________________________________________________________________________
<S>                                            <C>         <C>         <C>         <C>          <C>
Investment income (loss) - net                   ($12,132)    ($161)      ($103)      ($179)        $73,496
Net realized gain (loss) on investments               895       581           -        (206)          3,376
Net change in unrealized appreciation
 or depreciation of investments                    88,084     3,583       5,242       1,808         191,451
____________________________________________________________________________________________________________
Net increase (decrease) in net assets resulting
 from operations                                   76,847     4,003       5,139       1,423         268,323
____________________________________________________________________________________________________________
Contract Transactions
____________________________________________________________________________________________________________
Variable annuity contract purchase payments     2,077,508   152,294     145,957     286,858      10,077,549
Net transfers*                                     24,145    61,309       3,025      28,236         154,341
Contract terminations:
Surrender benefits                                (20,248)        -           -           -         (95,706)
____________________________________________________________________________________________________________
Increase from contract transactions             2,081,405   213,603     148,982     315,094      10,136,184
____________________________________________________________________________________________________________
Net assets at beginning of period                       -         -           -           -              
- -____________________________________________________________________________________________________________
Net assets at end of period                    $2,158,252  $217,606    $154,121    $316,517     $10,404,507
____________________________________________________________________________________________________________
Accumulation Unit Activity
____________________________________________________________________________________________________________
Units outstanding at beginning of period                -         -           -           -
Contract purchase payments                      2,088,753   150,807     145,262     286,995
Net transfers*                                     23,773    60,670       2,959      28,310
Contract terminations:
Surrender benefits                                (19,927)        -           -           -
____________________________________________________________________________________________________________
Units outstanding at end of period              2,092,599   211,477     148,221     315,305
____________________________________________________________________________________________________________
*Includes transfer activity from (to) other subaccounts and transfers from (to) IDS Life of New York's Fixed Account.
**Commenced operations on Dec. 2, 1993.
See accompanying notes to financial statements.
/TABLE
<PAGE>
PAGE 56
Notes to Financial Statements
___________________________________________________________________
1. Organization

IDS Life Account of New York SBS (the Variable Account), formerly
IDS Life of New York Account SLB, was established on Oct. 8, 1991
as a single unit investment trust of IDS Life Insurance Company of
New York (IDS Life of New York) under the Investment Company Act of
1940, as amended (the "1940 Act").  Operations of the Variable
Account commenced on March 15, 1993.

The Variable Account is comprised of various subaccounts.  Each
subaccount invests exclusively in shares of ten portfolios
(collectively, the Portfolios) of the Smith Barney Series Fund (the
mutual fund) or three funds of the IDS Life Retirement Annuity
Mutual Funds (collectively, the Funds).  The assets of each
subaccount of the Variable Account are not chargeable with
liabilities arising out of the business conducted by any other
Subaccount, Account or by IDS Life of New York.  Purchase payments
are allocated to any or all thirteen subaccounts or in the Fixed
Account of IDS Life of New York.  The purchase payments allocated
to the subaccounts are then invested in shares of the specific
Portfolio(s) or Fund(s) selected.

Smith Barney Series Fund (the mutual fund) is registered under the
1940 Act as a diversified, open-end management investment company.
The mutual fund currently offers a selection of ten Portfolios.
Purchase payments allocated to the Money Market (BMO) subaccount
invest in shares of the Money Market Portfolio,  the Intermediate
High Grade (BIH) subaccount invests in shares of the Intermediate
High Grade Portfolio; the Diversified Strategic Income (BDS)
subaccount invests in shares of the Diversified Strategic Income
Portfolio; the Equity Income (BEM) subaccount invests in shares of
the Equity Income Portfolio; the Equity Index (BEX) subaccount
invests in shares of the Equity Index Portfolio; the Growth &
Income (BGI) subaccount invests in shares of the Growth & Income
Portfolio;  the Appreciation (BAP) subaccount invests in shares of
the Appreciation Portfolio; the Total Return (BTR) subaccount
invests in shares of the Total Return Portfolio; the Emerging
Growth (BEG) subaccount invests in shares of the Emerging Growth
Portfolio; and the International Equity (BIE) subaccount invests in
shares of the International Equity Portfolio.

IDS Life Capital Resource Fund, Inc. and IDS Life Special Income
Fund, Inc. commenced operations Oct. 13, 1981. IDS Life Managed
Fund, Inc. commenced operations April 30, 1986. These mutual funds
are registered under the Investment Company Act of 1940 as
diversified, open-end management investment companies. Purchase
payments allocated to the Capital Resource (BCR) subaccount invest
in shares of IDS Life Capital Resource Fund; the Special Income
(BSI) subaccount invests in shares of IDS Life Special Income Fund;
and the Managed (BMG) subaccount invests in shares of IDS Life
Managed Fund.  Subaccounts BCR, BSI and BMG had no activity in the
period Nov. 28, 1994 (commencement of operations) to Dec. 31, 1994.

IDS Life Insurance Company, parent company of IDS Life of New York,
serves as investment manager and distributor for the Variable
Account and for the Funds. American Express Financial Corporation
serves as investment advisor to the Funds.  Smith Barney Inc.<PAGE>
PAGE 57
serves as distributor for the mutal fund.  Smith Barney Mutual
Funds Management Inc. serves as investment adviser to the Money
Market Portfolio, the Intermediate High Grade Portfolio, the
Diversified Strategic Income Portfolio, the Equity Income
Portfolio, the Growth & Income Portfolio, Appreciation Portfolio,
Total Return Portfolio and the International Equity Portfolio.  
Travelers Investment Management Company serves as investment
adviser to the Equity Index Portfolio.  American Capital Asset
Management, Inc. serves as investment adviser to the Emerging
Growth Portfolio. Smith Barney Global Capital Management, Inc.
serves as sub-investment adviser to the Diversified Strategic
Income Portfolio.  Smith Barney Mutual Funds Management Inc. serves
as administrator to each Portfolio.  Boston Safe Deposit and Trust
Company serves as the custodian for the Portfolios and the Funds.
___________________________________________________________________
2. Summary of Significant Accounting Policies

Investments in the Mutual Fund
Investments in shares of the Portfolio(s) of the mutual fund or in
shares of the Funds are stated at market value which is the net
asset value per share as determined by the respective portfolio or
fund.  Investment transactions are accounted for on the date the
shares are purchased and sold.  The cost of investments sold and
redeemed is determined on the average cost method.  Dividend
distributions received from the Portfolios or the Funds are
reinvested, net of any expense payable to IDS Life of New York, in
additional shares of the Portfolios or the Funds and are recorded
as income by the subaccounts on the ex-dividend date.

Unrealized appreciation or depreciation of investments in the
accompanying financial statements represents the subaccounts' share
of the Portfolios' or Funds' undistributed net investment income,
undistributed realized gain or loss and the unrealized appreciation
or depreciation on their investment securities.

Federal Income Taxes
IDS Life of New York is taxed as a life insurance company.  The
Variable Account is treated as part of IDS Life of New York for
federal income tax purposes. Under existing federal income tax law,
no income taxes are payable with respect to any investment income
of the Variable Account.
___________________________________________________________________
3.  Mortality and Expense Risk Fee

IDS Life of New York makes guarantees to the Variable Account that
possible future adverse changes in administrative expenses and
mortality experience of the annuitants will not affect the Variable
Account.  The mortality and expense risk fee paid to IDS Life of
New York is deducted daily and is equal, on an annual basis, to
1.25 percent of the daily net asset value of each subaccount.
___________________________________________________________________
4.  Variable Account Administrative Charge

IDS Life of New York deducts a daily charge equal, on an annual
basis, to 0.25 percent of the daily net asset value of each
subaccount.  It covers certain administrative and operating
expenses of the subaccounts incurred by IDS Life of New York such
as accounting, legal and data processing fees, and expenses <PAGE>
PAGE 58
involved in the preparation and distribution of reports and
prospectuses.
___________________________________________________________________
5.  Certificate Administrative Charge

IDS Life of New York deducts an administrative charge of $30 per
year on each certificate anniversary.  This charge reimburses IDS
Life of New York for expenses incurred in establishing and
maintaining the Annuity records. This charge cannot be
increased and does not apply after a retirement payment plan
begins. IDS Life of New York does not expect to profit from this
charge.
___________________________________________________________________
6.  Surrender Charge

IDS Life of New York will use a surrender charge to help it recover
certain expenses relating to the sale of the Annuity.  The
surrender charge will be deducted for surrenders during the first
six payment years following a purchase payment.  Charges by IDS
Life of New York for surrenders are not available on an individual
segregated asset account basis.  Charges for all segregated asset
accounts amount to $269,275 in 1994 and $151,536 in 1993.  Such
charges are not an expense of the subaccounts or Variable Account. 
They are deducted from contract surrender benefits paid by IDS Life
of New York.
___________________________________________________________________
7.  Investment Transactions

The subaccounts' purchases of Portfolio or Fund shares (net of
charges), including reinvestment of dividend distributions, were as
follows:

  <TABLE> <CAPTION>
                                                                          For the period
                                                                     from March 15, 1993
                                                                        (commencement of
                                                                          operations) to
  Subaccount     Investment                          Dec. 31, 1994         Dec. 31, 1993
  <S>          <C>                                       <C>             <C>
  BMO          Money Market Portfolio                    $    506,374    $   596,640
  BIH          Intermediate High Grade Portfolio              366,264        770,636
  BDS          Diversified Strategic Income Portfolio       1,258,046      2,192,546
  BEM          Equity Income Portfolio                        773,605      1,675,871
  BEX          Equity Index Portfolio                         185,530      1,140,208
  BGI          Growth & Income Portfolio                      637,649      1,447,774
  BAP          Appreciation Portfolio                       1,309,065      2,109,028
  *BTR         Total Return Portfolio                         858,531        245,435
  *BEG         Emerging Growth Portfolio                      661,027        176,481
  *BIE         International Equity Portfolio               1,772,919        342,483
  **BCR        IDS Life Capital Resource Fund                       -              -
  **BSI        IDS Life Special Income Fund, Inc.                   -              -
  **BMG        IDS Life Managed Fund, Inc.                          -              -
                                                          $ 8,329,010    $10,697,102
  </TABLE>
*Commenced operations on Dec. 2, 1993.
**Commenced operations on Nov. 28, 1994.
<PAGE>
PAGE 59

IDS Life of New York Account SBS

Annual Financial Information

Report of Independent Auditors

The Board of Directors
IDS Life Insurance Company of New York

We have audited the accompanying individual and combined statements
of net assets of the segregated asset subaccounts of IDS Life of
New York Account SBS (comprising, respectively, the BMO, BIH, BDS,
BEM, BEX, BGI, BAP, BTR, BEG, BIE, BCR, BSI and BMG subaccounts) as
of December 31, 1994, and the related statements of operations for
the year then ended, except for the BCR, BSI and BMG subaccounts
which are for the period November 28, 1994 (commencement of
operations) to December 31, 1994 and the statements of changes in
net assets for the periods from March 15, 1993 (commencement of
operations) to December 31, 1993 and for the year ended December
31, 1994, except for the  BTR, BEG and BIE subaccounts which are
for the periods December 2, 1993 (commencement of operations) to
December 31, 1993 and for the year ended December 31, 1994 and the
BCR, BSI and BMG subaccounts which are for the period November 28,
1994 (commencement of operations) to December 31, 1994. These
financial statements are the responsibility of the management of
IDS Life Insurance Company of New York. Our responsibility is to
express an opinion on these financial statements based on our
audits.

We conducted our audits in accordance with generally accepted
auditing standards. Those standards require that we plan and
perform the audit to obtain reasonable assurance about whether the
financial statements are free of material misstatement. An audit
includes examining, on a test basis, evidence supporting the
amounts and disclosures in the financial statements. Our procedures
included confirmation by the underlying affiliated mutual fund of
securities owned at December 31, 1994. An audit also includes
assessing the accounting principles used and significant estimates
made by management, as well as evaluating the overall financial
statement presentation. We believe that our audits provide a
reasonable basis for our opinion.

In our opinion, the financial statements referred to above present
fairly, in all material respects, the individual and combined
financial position of the segregated asset subaccounts of IDS Life
of New York Account SBS at December 31, 1994 and the individual and
combined results of their operations and the changes in their net
assets for the periods described in the first paragraph, in
conformity with generally accepted accounting principles.


ERNST & YOUNG LLP
Minneapolis, Minnesota
March 17, 1995

<PAGE>
PAGE 60
<TABLE><CAPTION>
IDS LIFE INSURANCE COMPANY OF NEW YORK
BALANCE SHEETS
December 31,

ASSETS                                                                            1994                           1993   
<S>                                                                            <C>                            <C> 
                                                                                             (thousands)
Investments:
Fixed maturities:
Held to maturity, at amortized cost (Fair value: 1994, $653,080)               $  686,483                     $         -
 Available for sale, at fair value (Amortized cost: 1994, $474,599)               455,103                               -
Investment securities, at amortized cost (Fair value: 1993, 
$1,240,593)                                                                             -                       1,171,023
Mortgage loans on real estate
(Fair value:  1994, $157,085; 1993, $124,030)                                     164,916                         123,337
Policy loans                                                                       14,899                          12,952
Other investments                                                                   1,524                           2,239

Total investments                                                               1,322,925                       1,309,551

Cash and cash equivalents                                                           5,262                               -

Accrued investment income                                                          21,517                          21,342

Deferred policy acquisition costs                                                 100,078                          87,891

Other assets                                                                        1,584                           2,270

Assets held in segregated asset accounts,
primarily common stocks at market                                                 506,208                         380,796

 Total assets                                                                  $1,957,574                     $ 1,801,850
                                                                                =========                       ========= 
                    See accompanying notes to financial statements.<PAGE>
PAGE 61
IDS LIFE INSURANCE COMPANY OF NEW YORK
BALANCE SHEETS (continued)
December 31,

LIABILITIES AND STOCKHOLDER'S EQUITY                                              1994                           1993   
      (thousands)       


Liabilities:
Fixed annuities - future policy benefits                                       $ 1,087,367                    $ 1,059,005
Universal life-type insurance - future policy benefits                             127,871                        120,917
Traditional life, disability income and long-term care
insurance - future policy benefits                                                  40,546                         40,045
Policy claims and other policyholders' funds                                         3,217                          2,347
Deferred income taxes                                                                2,044                         13,018
Amounts due to brokers                                                                   -                          4,952
Other liabilities                                                                   18,600                         20,311
Liabilities related to segregated asset accounts                                   506,208                        380,796

Total liabilities                                                                1,785,853                      1,641,391

Stockholder's equity:
Capital stock, $10 par value per share;
200,000 shares authorized, issued and outstanding                                    2,000                          2,000
Additional paid-in capital                                                          49,000                         49,000
Net unrealized gain (loss) on investments                                          (12,369)                            24
Retained earnings                                                                  133,090                        109,435

Total stockholder's equity                                                         171,721                        160,459

Total liabilities and stockholder's equity                                     $ 1,957,574                    $ 1,801,850
                                                                                 =========                      =========

Commitments and contingencies (Note 7)

                               See accompanying notes to financial statements.
/TABLE
<PAGE>
PAGE 62
<TABLE><CAPTION>
IDS LIFE INSURANCE COMPANY OF NEW YORK
STATEMENTS OF INCOME
Years ended December 31,
                     
                                                                            1994               1993                1992
                                                                                          (thousands)
<S>                                                                     <C>               <C>                 <C>
Revenues:
Traditional life, disability income and long-term care
insurance premiums                                                      $  7,846          $  7,110            $  6,282
Policyholder and contractholder charges                                   11,607             9,634               8,359
Mortality and expense risk fees                                            4,562             2,904               1,696
Net investment income                                                    108,143           110,147             102,071
Net gain on investments                                                      957             1,334               2,478
Total revenues                                                           133,115           131,129             120,886

Benefits and expenses:
Death and other benefits - traditional life disability income
and long-term care insurance                                               6,016             5,715               5,705
Death and other benefits - universal life-type insurance
and investment contracts                                                   3,773             2,465               2,133
Increase (decrease) in liabilities for future policy benefits
for traditional life, disability income and long-term care
insurance                                                                    506            (1,343)               (855)
Interest credited on universal life-type insurance and
investment contracts                                                      65,018            68,987              68,487
Amortization of deferred policy acquisition costs                         12,994            10,434               8,137
Other insurance and operating expenses                                     8,359             7,652               6,403
Total benefits and expenses                                               96,666            93,910              90,010

Income before income taxes                                                36,449            37,219              30,876


Income taxes                                                              12,794            13,335              10,914


Net income                                                              $ 23,655          $ 23,884            $ 19,962
                                                                          ======            ======              ======

See accompanying notes to financial statements.
/TABLE
<PAGE>
PAGE 63
<TABLE><CAPTION>
IDS LIFE INSURANCE COMPANY OF NEW YORK
STATEMENTS OF CASH FLOWS
Years ended December 31,

                                                                          1994               1993               1992 
<S>                                                                    <C>                <C>                <C>
                                                                                        (thousands)
Cash flows from operating activities:
Net income                                                              $23,655           $23,884             $19,962
Adjustments to reconcile net income to net cash
provided by operating activities:
Issuance - Policy loans, excluding universal life-type insurance         (1,365)           (1,044)               (635)
Repayment - Policy loans, excluding universal life-type insurance           849               455                 327
Change in accrued investment income                                        (175)           (1,476)             (1,797)
Change in deferred policy acquisition costs, net                        (11,522)          (10,622)            (10,974)
Change in liabilities for future policy benefits for traditional life,
disability income and long-term care insurance                              501              (939)               (855)
Change in policy claims and other policyholders' funds                      870               282                 592
Change in deferred income taxes                                          (4,321)             (449)              1,302
Change in other liabilities                                              (1,711)            4,348                 466
Amortization of premium (accretion of discount), net                      2,464            (1,598)             (1,410)
Net gain on investments                                                    (957)           (1,334)             (2,478)
Premiums related to universal life-type insurance                        19,522            15,141              13,919
Surrenders and death benefits related to universal life-
type insurance                                                          (13,208)           (9,785)             (5,976)
Interest credited to account balances related to universal life-
 type insurance                                                           6,640             6,892               7,168
Policyholder and contractholder charges, non-cash                        (6,000)           (5,663)             (5,452)
Other, net                                                                  689              (780)                700
Net cash provided by operating activities                               $15,931           $17,312             $14,859

See accompanying notes to financial statements.
<PAGE>
PAGE 64
IDS LIFE INSURANCE COMPANY OF NEW YORK
STATEMENTS OF CASH FLOWS (continued)
Years ended December 31,

                                                                       1994               1993               1992
                                                                                       (thousands)

Cash flows from investing activities:
Fixed maturities held to maturity:
Purchases                                                          $  (36,560)           $       -           $        -
Maturities, sinking fund payments and calls                            78,757                    -                    -
Sales                                                                   2,649                    -                    -
Fixed maturities available for sale:
Purchases                                                            (117,965)                   -                    -
Maturities, sinking fund payments and calls                            70,316                    -                    -
Sales                                                                  14,533                    -                    -
Investment securities:
Purchases                                                                   -             (331,900)            (420,607)
Maturities, sinking fund payments and calls                                 -              265,059              210,543
Sales                                                                       -               28,519               67,306
Other investments, excluding policy loans:
Purchases                                                             (47,353)             (65,202)             (19,430)
Sales                                                                   2,975                2,568                  867
Change in amounts due to brokers                                       (4,952)             (10,448)              12,249
Net cash used in investing activities                                 (37,600)            (111,404)            (149,072)

Cash flows from financing activities:
Activity related to investment contracts:
Considerations received                                              168,947               149,269              159,913
Surrenders and death benefits                                       (198,963)             (119,158)             (80,632)
 Interest credited to account balances                                58,378                62,250               61,319
Universal life-type insurance policy loans:
Issuance                                                              (3,907)               (3,403)              (3,668)
Repayment                                                              2,476                 1,886                1,548
Cash dividend to parent                                                    -                     -               (6,000)
Net cash provided by financing activities                             26,931                90,844               132,480


Net increase (decrease) in cash and cash
equivalents                                                            5,262                (3,248)              (1,733)

Cash and cash equivalents at beginning of year                             -                 3,248                4,981

Cash and cash equivalents at end of year                           $   5,262             $       -           $    3,248
                                                                       =====                 =====                =====

See accompanying notes to financial statements.
/TABLE
<PAGE>
PAGE 65
IDS LIFE INSURANCE COMPANY OF NEW YORK
NOTES TO FINANCIAL STATEMENTS
($ thousands)

1.   Summary of significant accounting policies
     
     Nature of business
     
     IDS Life Insurance Company of New York (the Company) is
     engaged in the insurance and annuity business in the state of
     New York and sells various forms of fixed and variable
     individual life insurance, individual disability income and
     long-term care insurance, and single and installment premium
     fixed and variable annuities.
     
     Basis of presentation
     
     The Company is a wholly owned subsidiary of IDS Life Insurance
     Company (IDS Life), which is a wholly owned subsidiary of
     American Express Financial Corporation (formerly IDS Financial
     Corporation), which is a wholly owned subsidiary of American
     Express Company.  The accompanying financial statements have
     been prepared in conformity with generally accepted accounting
     principles which vary in certain respects from reporting
     practices prescribed or permitted by state insurance
     regulatory authority as reconciled in Note 11.
     
     Investments
     
     As of Jan. 1, 1994, the Company adopted Statement of Financial
     Accounting Standards (SFAS) No. 115, "Accounting for Certain
     Investments in Debt and Equity Securities."  Under SFAS No.
     115, fixed maturities that the Company has both the positive
     intent and the ability to hold to maturity are classified as
     held to maturity and carried at amortized cost.  All other
     fixed maturities and all marketable equity securities are
     classified as available for sale and carried at fair value. 
     Unrealized gains and losses on securities classified as
     available for sale are carried as a separate component of
     stockholder's equity.  The effect of adopting SFAS No. 115 was
     to increase stockholder's equity by approximately $12 million,
     net of tax, as of Jan. 1, 1994, but the adoption had no impact
     on the Company's net income.
     
     Management determines the appropriate classification of fixed
     maturities at the time of purchase and reevaluates the
     classification at each balance sheet date.     
     
     Mortgage loans on real estate are carried principally at the
     unpaid principal balances of the related loans.  Policy loans
     are carried at the aggregate of the unpaid loan balances which
     do not exceed the cash surrender values of the related
     policies.  Other  investments include interest rate caps and 
<PAGE>
PAGE 66
1.   Summary of significant accounting policies (continued)
 
     equity securities.  When evidence indicates a decline, which
     is other than temporary, in the underlying value or earning
     power of individual investments, such investments are written
     down to the fair value by a charge to income.  Equity
     securities are carried at market value and the related
     netunrealized appreciation or depreciation is reported as a
     credit or charge to stockholder's equity.

     Realized investment gain or loss is determined on an
     identified cost basis.
     
     Prepayments are anticipated on certain investments in
     mortgage-backed securities in determining the constant
     effective yield used to recognize interest income.  Prepayment
     estimates are based on information received from brokers who
     deal in mortgage-backed securities.

     Statement of cash flows

     The Company considers investments with a maturity at the date
     of their acquisition of three months or less to be cash
     equivalents.  These securities are carried principally at
     amortized cost which approximates fair value.

     Supplementary information to the statement of cash flows for
     the years ended Dec. 31 is summarized as follows:

                                           1994      1993     1992 
     Cash paid during the year for:
       Income taxes                       $17,386  $14,138  $9,193
       Interest on borrowings                 147      235     132

     Recognition of profits on annuity contracts and insurance
     policies

     The Company issues single premium deferred annuity contracts
     that provide for a service fee (surrender charge) at annually
     decreasing rates upon withdrawal of the annuity accumulation
     value by the contract owner.  No sales fee is deducted from
     the contract considerations received on these contracts ("no
     load" annuities).  All of the Company's single premium
     deferred annuity contracts provide for crediting the contract
     owners' accumulations at specified rates of interest.  Such
     rates are revised by the Company from time to time based on
     changes in the market investment yield rates for fixed-income
     securities.

     Profits on single premium deferred annuities and installment
     annuities are recognized by the Company over the lives of the
     contracts and represent the excess of investment income earned
     from investment of contract considerations over interest
     credited to contract owners and other expenses.
 <PAGE>
PAGE 67
1.   Summary of significant accounting policies (continued)

     The retrospective deposit method is used in accounting for
     universal life-type insurance.  This method recognizes profits
     over the lives of the policies in proportion to the estimated
     gross profits expected to be realized.

     Premiums on traditional life, disability income and long-term
     care insurance policies are recognized as revenue when
     collected or due, and related benefits and expenses are
     associated with premium revenue in a manner that results in
     recognition of profits over the lives of the insurance
     policies.  This association is accomplished by means of the
     provision for future policy benefits and the deferral and
     subsequent amortization of policy acquisition costs.

     Deferred policy acquisition costs

     The costs of acquiring new business, principally sales
     compensation, policy issue costs, underwriting and certain
     sales expenses, have been deferred on insurance and annuity
     contracts. The deferred acquisition costs for single premium
     deferred annuities and installment annuities are amortized
     based upon surrender charge revenue and a portion of the
     excess of investment income earned from investment of the
     contract considerations over the interest credited to contract
     owners.  The costs for universal life-type insurance are
     amortized over the lives of the policies as a percentage of
     the estimated gross profits expected to be realized on the
     policies.  For traditional life, disability income and long-
     term care insurance policies, the costs are amortized over an
     appropriate period in proportion to premium revenue.  

     Liabilities for future policy benefits

     Liabilities for universal life-type insurance, single premium
     deferred annuities and installment annuities are accumulation
     values.

     Liabilities for fixed annuities in a benefit status are based
     on the Progressive Annuity Table with interest at 5 percent,
     the 1971 Individual Annuity Table with interest at 7 percent
     or 8.25 percent, or the 1983a Table with various interest
     rates ranging from 5.5 percent to 9.5 percent, depending on
     year of issue.

     Liabilities for future benefits on traditional life insurance
     have been computed principally by the net level premium
     method, based on anticipated rates of mortality (approximating
     the 1965-1970 Select and Ultimate Basic Table for policies
     issued after 1980 and the 1955-1960 Select and Ultimate Basic
     Table for policies issued prior to 1981 and the 1975-1980
     Select and Ultimate Basic Table for term insurance policies 
<PAGE>
PAGE 68
1.   Summary of significant accounting policies (continued)

     issued after 1986), policy persistency  derived from IDS
     Life's experience data (first-year rates ranging from
     approximately 70 percent to 90 percent and increasing rates
     thereafter), and estimated future investment yields of 4
     percent for policies issued before 1974 and 5.25 percent for
     policies issued from 1974 to 1980.  Cash value plans issued in
     1980 and later assume future investment rates that grade from
     9.5 percent to 5 percent over 20 years.  Term insurance issued
     from 1981 to 1984 assumes an 8 percent level investment rate,
     and term insurance issued after 1984 assumes investment rates
     that grade from 10 percent to 6 percent over 20 years.

     Liabilities for future disability income policy benefits have
     been computed principally by the net level premium
     method,based on the 1964 Commissioners Disability Table with
     the 1958 Commissioners Standard Ordinary Mortality Table at 3
     percent interest for 1980 and prior, 8 percent interest for
     persons disabled from 1981 to 1991, 7.7 percent interest for
     persons disabled in 1992 and 6 percent interest for persons
     disabled after 1992.

     Liabilities for future benefits on long-term care insurance
     have been computed principally by the net level premium
     method, using morbidity rates based on the 1985 National
     Nursing Home Survey and mortality rates based on the 1983a
     Table.  The interest rate basis is 9.5 percent grading to 7
     percent over ten years for policies issued from 1989 to 1992,
     7.75 percent grading to 7 percent over four years for policies
     issued after 1992, 8 percent for claims incurred in 1989 to
     1991, 7.7 percent for claims incurred in 1992 and 6 percent
     for claims incurred after 1992.

     Reinsurance

     The maximum amount of life insurance risk retained by the
     Company on any one life is $750 of life and waiver of premium
     benefits plus $50 of accidental death benefits.  The maximum
     amount of disability income risk retained by the Company on
     any one life is $6 of monthly benefit for benefit periods
     longer than three years.  The excesses are reinsured with
     other life insurance companies on a yearly renewable term
     basis.

     Federal income taxes

     The Company's taxable income is included in the consolidated
     federal income tax return of American Express Company.  The
     Company provides for income taxes on a separate return basis,
     except that, under an agreement between American Express
     Financial Corporation and American Express Company, tax
     benefit is recognized for losses to the extent they can be 
<PAGE>
PAGE 69
1.   Summary of significant accounting policies (continued)

     used on the consolidated tax return.  It is the policy of
     American Express Financial Corporation and its subsidiaries
     that American Express Financial Corporation will reimburse a
     subsidiary for any tax benefit.

     Included in other liabilities at Dec. 31, 1994 and 1993 are
     $3,161 and $3,462, respectively, payable to IDS Life for
     federal income taxes.

     Segregated asset account business

     The segregated asset account assets and liabilities represent
     funds held for the exclusive benefit of the variable annuity
     and variable life insurance contract owners.  The Company
     receives a monthly cost of insurance charge and receives a
     minimum death benefit guarantee fee from variable life
     insurance segregated asset accounts and a mortality and
     expense assurance fee from the variable annuity and variable
     life insurance segregated asset accounts.

     The Company makes contractual mortality assurances to the
     variable annuity contract owners that the net assets of the
     segregated asset accounts will not be affected by future
     variations in the actual life expectancy experience of the
     annuitants and the beneficiaries from the mortality
     assumptions implicit in the annuity contracts.  The Company
     makes periodic fund transfers to, or withdrawals from, the
     segregated asset accounts for such actuarial adjustments for
     variable annuities that are in the benefit payment period. 
     The Company guarantees, for the variable life insurance
     policyholders, the contractual insurance rate and that the
     death benefit will never be less than the death benefit at the
     date of issuance.
       
     Reclassification

     Certain 1993 and 1992 amounts have been reclassified to
     conform to the 1994 presentation.
                                       
2.   Investments

     Fair values of investments in fixed maturities represent
     quoted market prices and estimated  values when quoted prices
     are not available.  Estimated values are determined by
     established procedures involving, among other things, review
     of market indices, price levels of current offerings of
     comparable issues, price estimates and market data from
     independent brokers and financial files.
     
     Changes in net unrealized appreciation (depreciation) of
     investments for the years ended Dec. 31 are summarized as
     follows:
     <PAGE>
PAGE 70
2.   Investments (continued)

                                   1994          1993        1992
         Fixed maturities:
           Held to maturity     $(84,244)      $    --     $    --
           Available for sale    (38,226)           --          --
         Investment securities        --        25,350     (10,980)

     Net gain (loss) on investments for the years ended Dec. 31 is
     summarized as follows:

                                   1994          1993        1992

        Fixed maturities          $948          $1,316      $2,752
        Other investments            9              18        (274)
                                  $957          $1,334      $2,478
                                  ====          ======      ======

     The amortized cost, gross unrealized gains and losses and fair
     value of investments in fixed maturities and equity securities
     at Dec. 31, 1994 are as follows:
<TABLE><CAPTION>
                                            Gross            Gross
                          Amortized       Unrealized       Unrealized          Fair
Held to maturity           Cost             Gains            Losses            Value
<S>                       <C>               <C>              <C>               <C>
U.S. Government agency
  obligations             $    398          $    2           $    18           $    382
Corporate bonds and
  obligations              622,422           6,564            33,976            595,010
Mortgage-backed
  securities                63,663             580             6,555             57,688
                          $686,483          $7,146           $40,549           $653,080
                           =======           =====            ======            =======  

                                             Gross            Gross
                         Amortized        Unrealized       Unrealized              Fair
Available for sale         Cost              Gains            Losses               Value

U.S. Government agency
  obligations            $  10,000         $     --          $   135           $   9,865
State and municipal
  obligations                  104                1               --                 105
Corporate bonds and
  obligations              142,447            2,632            2,447             142,632
Mortgage-backed
  securities               322,048              381           19,928             302,501
Total fixed maturities     474,599            3,014           22,510             455,103

Equity securities              332               --              197                 135
                          $474,931           $3,014          $22,707            $455,238
                           =======            =====           ====== 
</TABLE>
<PAGE>
PAGE 71
2.   Investments (continued)

     The change in net unrealized gain (loss) on available for sale
     securities included as a separate component of stockholder's 
     equity was $(12,393) in 1994.
     
     The amortized cost, gross unrealized gains and losses, and
     fair value of investments in fixed maturities carried at
     amortized cost at Dec. 31, 1993 are as follows:
<TABLE><CAPTION>
     
                         Amortized        Unrealized       Unrealized              Fair
1993                       Cost              Gains            Losses               Value
<S>                     <C>                <C>                <C>             <C>
U.S. Government agency
  obligations            $    400          $    40            $   --          $      440
State and municipal
  obligations                 105               15                --                 120
Corporate bonds and
  obligations             745,822           60,482             1,858             804,446
Mortgage-backed
  securities              424,696           15,265             4,374             435,587
                       $1,171,023          $75,802            $6,232          $1,240,593
                       ==========          =======            ======          ==========
</TABLE>
     At Dec. 31, 1993, gross and net unrealized appreciation on
     equity securities amounted to $18.  The fair value of equity
     securities was $190 at Dec. 31, 1993.
     
     The amortized cost and fair value of investments in fixed
     maturities at Dec. 31, 1994 by contractual maturity are shown
     below.  Expected maturities will differ from contractual
     maturities because borrowers may have the right to call or
     prepay obligations with or without call or prepayment
     penalties.

                                     Amortized            Fair
Held to maturity                        Cost              Value
     
Due in one year or less               $  4,952          $  5,002
Due from one to five years              88,837            89,253 
Due from five to ten years             386,356           371,007
Due in more than ten years             142,675           130,130
Mortgage-backed securities              63,663            57,688
                                      $686,483          $653,080
                                       =======           =======

                                     Amortized            Fair
Available for sale                      Cost              Value
     
Due from one to five years            $ 92,886          $  93,117 
Due from five to ten years              37,524             38,494
Due in more than ten years              22,141             20,991
Mortgage-backed securities             322,048            302,501
                                      $474,599           $455,103
                                       =======            =======
<PAGE>
PAGE 72
2.   Investments (continued)

     During the year ended Dec. 31, 1994, fixed maturities
     classified as held to maturity were sold with proceeds of
     $2,649 and gross realized gains and losses on such sales were
     $nil and $86, respectively.  The sale of these fixed
     maturities was due to credit deterioration.

     In addition, fixed maturities available for sale were sold
     during 1994 with proceeds of $14,533 and gross realized gains
     and losses on such sales were $181 and $308, respectively.
     
     Proceeds from sales of investments in fixed maturities during
     1993 were $28,519.  During 1993,  gross gains of $4,022 and
     gross losses of $2,213 were realized on those sales.
     
     At Dec. 31, 1994, bonds carried at $264 were on deposit with
     the state of New York as required by law.
     
     Net investment income for the years ended Dec. 31 is
     summarized as follows:


                                      1994       1993        1992  
Interest on fixed maturities       $  93,800  $ 100,940   $  96,452
Interest on mortgage loans            13,226      8,424       4,908
Other investment income                1,219      1,220         841
Interest on cash equivalents             363         63         378
                                     108,608    110,647     102,579
Less investment expenses                 465        500         508
                                    $108,143   $110,147    $102,071

     At Dec. 31, 1994, investments in fixed maturities comprised
     86 percent of the Company's total invested assets.  Securities
     are rated by Moody's and Standard & Poor's (S&P) except for
     securities  carried at approximately $129 million which are
     rated by American Express Financial Corporation internal
     analysts using criteria similar to Moody's and S&P.  A summary
     of investments in fixed maturities, at amortized cost, by
     rating on Dec. 31 is as follows: 

     Rating                        1994              1993   
     Aaa/AAA                    $  393,736       $   425,404
     Aa/AA                          18,857            13,285
     Aa/A                            9,710            14,213
     A/A                           191,694           139,878
     A/BBB                          57,206            62,817
     Baa/BBB                       340,271           343,233
     Baa/BB                         48,552            55,812
     Below investment grade        101,056           116,381
                                $1,161,082        $1,171,023
                                ==========        ==========

<PAGE>
PAGE 73
2.   Investments (continued)

     At Dec. 31, 1994, 93 percent of the securities rated Aaa/AAA
     are GNMA, FNMA and FHLMC mortgage-backed securities.  No
     holdings of any other issuer are greater than 1 percent of the
     Company's total investments in fixed maturities. 
       
     At Dec. 31, 1994, approximately 12.5 percent of the Company's
     invested assets were mortgage loans on real estate.  Summaries
     of mortgage loans by region and by type of real estate are as
     follows:
<TABLE><CAPTION>
                                         Dec. 31, 1994                Dec. 31, 1993      
                                      On Balance    Commitments    On Balance    Commitments
      Region                            Sheet       to Purchase      Sheet       to Purchase
      <S>                             <C>               <C>        <C>            <C>
      West North Central              $  26,660         $ --       $  27,349      $  1,713
      East North Central                 35,018           --          28,349         2,569
      South Atlantic                     39,516           18          26,423         8,279
      Middle Atlantic                    24,061           --          15,912         8,564
      Pacific                            13,297           --          12,224            --
      Mountain                           15,218           --           6,723         4,568
      New England                         9,674           --           4,858         2,855
      East South Central                  1,629           --           1,646            --
      West South Central                    288           --             298            --
                                        165,361           18         123,782        28,548
      Less allowance for losses             445           --             445            --   
                                       $164,916          $18        $123,337       $28,548
                                        =======           ==         =======

                                       Dec. 31, 1994                Dec. 31, 1993      
                                      On Balance    Commitments    On Balance    Commitments
      Region                            Sheet       to Purchase      Sheet       to Purchase
      Apartments                       $  65,389         $18        $ 47,178       $15,130
      Department/retail stores            57,608          --          38,253         9,706 
      Office buildings                    13,107          --          11,475         1,142
      Industrial buildings                13,583          --          13,781         1,142
      Medical buildings                    6,704          --           5,229         1,428
      Nursing/retirement                   6,644          --           5,507            --
      Other                                2,038          --           2,061            --
      Hotels/motels                          288          --             298            --
                                         165,361          18         123,782        28,548 
      Less allowance for losses              445          --             445            --
                                        $164,916         $18        $123,337       $28,548
                                         =======          ==        ======== 
</TABLE>
     Mortgage loan fundings are restricted by state insurance
     regulatory authority to 80 percent or less of the market value
     of the real estate at the time of origination of the loan. 
     The Company holds the mortgage document, which gives the right
     to take possession of the property if the borrower fails to
     perform according to the terms of the agreement.  The fair
     value of the mortgage loans is determined by a discounted cash
     <PAGE>
PAGE 74
2.   Investments (continued)

     flow analysis using mortgage interest rates currently offered
     for mortgages of similar maturities.  Commitments to purchase
     mortgages are made in the ordinary course of business.  The
     fair value of the mortgage commitments is $nil.

3.   Income taxes

     The Company qualifies as a life insurance company for federal
     income tax purposes.  As such, the Company is subject to the
     Internal Revenue Code provisions applicable to life insurance
     companies.

     Income tax expense consists of the following:

                                         1994      1993      1992
     Federal income taxes:
         Current                       $16,419   $13,164   $  9,037
         Deferred                       (4,320)     (449)     1,302
                                        12,099    12,715     10,339

      State income taxes-current           695       620        575
      Income tax expense               $12,794   $13,335    $10,914
                                         =====     =====      =====

     Increases (decreases) to the federal tax provision applicable
     to pretax income based on the statutory rate are attributable
     to:
<TABLE><CAPTION>
                                 1994                   1993                  1992        
                                Provision  Rate        Provision  Rate       Provision Rate
<S>                             <C>        <C>         <C>        <C>        <C>       <C>
Federal income taxes based
 on the statutory rate          $12,757    35.0%       $13,026    35.0%      $10,498   34.0%
Increases (decreases)
 are attributable to:
  Tax-excluded interest
    and dividend income            (554)   (1.5)          (557)   (1.5)         (429)  (1.4)
  Other, net                       (104)   (0.3)           246     0.7           270    0.9
Federal income taxes            $12,099    33.2%       $12,715    34.2%      $10,339   33.5%
                                 ======     ===          =====     ===         =====    ===
</TABLE>
     A portion of life insurance company income earned prior to
     1984 was not subject to current taxation but was accumulated,
     for tax purposes, in a "policyholders' surplus account."  At
     Dec. 31, 1994, the Company had a policyholders' surplus
     account balance of $798.  The policyholders' surplus account
     is only taxable if dividends to the stockholder exceed the
     stockholder's surplus account or if the Company is liquidated. 
     Deferred income taxes of $279 have not been established
     because no distributions of such amounts are contemplated.

<PAGE>
PAGE 75
3.   Income taxes (continued)

     Significant components of the Company's deferred tax assets
     and liabilities as of Dec. 31  are as follows:

                                                 1994       1993  
        Deferred tax assets:
        Policy reserves                          $21,567    $15,683
        Investments                                3,331         --
        Other                                      2,991      1,543
          Total deferred tax assets               27,889     17,226


        Deferred tax liabilities:
        Deferred policy acquisition costs         29,933     27,250
        Investments                                   --      2,994
          Total deferred tax
            liabilities                           29,933     30,244
          Net deferred tax liabilities           $ 2,044    $13,018
                                                   =====      =====

     The Company is required to establish a "valuation allowance"
     for any portion of the deferred tax assets that management
     believes will not be realized.  In the opinion of management,
     it is more likely than not that the Company will realize the
     benefit of the deferred tax assets, and, therefore, no such
     valuation allowance has been established.

4.   Stockholder's equity

     Retained earnings available for distribution as dividends to
     the parent are limited to the Company's surplus as determined
     in accordance with accounting practices prescribed by state
     insurance regulatory authority.  Statutory unassigned surplus
     aggregated $70,974 as of Dec. 31, 1994 and $52,642 as of Dec.
     31, 1993 (see Note 3 with respect to the income tax effect of
     certain distributions).  In addition, any dividend
     distributions in 1994 in excess of approximately $7,097 would
     require approval of the New York Insurance Department.    

     Dividends paid to parent were $nil in 1994, $nil in 1993 and
     $6,000 in 1992.
     
5.   Retirement plan and services

     The Company participates in the retirement plan of American
     Express Financial Corporation which covers all permanent
     employees age 21 and over who have met certain employment
     requirements.  The benefits are based on years of service and
     the employee's monthly average of basic annual salary rates in
     effect on January 1, or such other date as determined by
     American Express Financial Corporation, of the highest five
     consecutive annual salaries of the last 10 years.  American 
<PAGE>
PAGE 76
5.   Retirement plan and services (continued)

     Express Financial Corporation's policy is to fund retirement
     plan costs accrued subject to ERISA and federal income tax
     considerations.  The Company's share of the total net periodic
     pension cost was $nil in 1994, 1993 and 1992.

     The Company has a "Sales Benefit Plan" which is an unfunded,
     noncontributory retirement plan for all eligible financial
     advisors.  Total plan costs for 1994, 1993 and 1992, which are
     calculated on the basis of commission earnings of the
     individual financial advisors, were $1,372, $1,042 and $1,164,
     respectively.  Such costs are included in deferred policy
     acquisition costs.
     
     The Company also participates in defined contribution pension
     plans of American Express Financial Corporation which cover
     all employees who have met certain employment requirements. 
     Company contributions to the plans are a percent of either
     each employee's eligible compensation or basic contributions. 
     Costs of these plans charged to operations in 1994, 1993 and
     1992 were $251, $201 and $144, respectively.

     The Company participates in defined benefit health care plans
     of American Express Financial Corporation that provide health
     care and life insurance benefits to retired employees and
     retired financial advisors.  The plans include participant
     contributions and service-related eligibility requirements. 
     Upon retirement, such employees are considered to have been
     employees of American Express Financial Corporation.  American
     Express Financial  Corporation expenses these benefits and
     allocates the expenses to its subsidiaries.  Accordingly,
     costs of such benefits to the Company are included in employee
     compensation and benefits and cannot be identified on a
     separate company basis.  At Dec. 31, 1994, the total
     accumulated post retirement benefit obligation, determined in
     accordance with SFAS 106 and based on an assumed interest rate
     of 8.75 percent and a health care cost trend rate of 7
     percent, has been recorded as a liability by American Express
     Financial Corporation.

6.   Incentive plan and operating expenses

     The Company maintains a "Persistency Payment Plan."  Under the
     terms of this plan, financial advisors earn additional
     compensation based on the volume and persistency of insurance
     sales.  The total costs for the plan for 1994, 1993 and 1992
     were $1,287, $1,387 and $1,252, respectively.  Such costs are
     included in deferred policy acquisition costs.

     Charges by IDS Life and American Express Financial Corporation
     for the use of joint facilities, marketing services and other
     services aggregated $9,314, $7,421 and $6,914 for 1994, 1993
     and 1992, respectively.  Certain of the costs assessed to the
     Company are included in deferred policy acquisition costs.<PAGE>
PAGE 77
7.   Commitments and contingencies

     At Dec. 31, 1994 and 1993, traditional life insurance and
     universal life-type insurance in force aggregated $3,155,571
     and $2,933,830, respectively, of which $162,956 and $172,973
     were reinsured at the respective year ends. 

     In addition, the Company has a "stop loss" reinsurance
     agreement with IDS Life covering ordinary life benefits.  IDS
     Life agrees to pay all death benefits incurred each year which
     exceed 125 percent of normal claims, where "normal" claims are
     defined in the agreement as .095 percent of the mean retained
     life insurance in force.  Premiums ceded to IDS Life amounted
     to $76, $67 and $60 for the years ended Dec. 31, 1994, 1993
     and 1992, respectively.  Claim recoveries under the terms of
     this reinsurance agreement were $nil in 1994, $nil in 1993 and
     $534 in 1992.

     Premiums ceded to reinsurers other than IDS Life amounted to
     $721, $741 and $773 for the years ended Dec. 31, 1994, 1993
     and 1992, respectively.  Reinsurance recovered from reinsurers
     other than IDS Life amounted to $14, $379 and $186 for the
     years ended Dec. 31, 1994, 1993 and 1992. 

     Reinsurance contracts do not relieve the Company from its
     primary obligations to policyholders.

     The Company has an agreement to assume a block of extended
     term  life insurance business.  The amount of insurance in
     force related to this agreement was $447,317 and $512,555 at
     Dec. 31, 1994 and 1993, respectively.  The accompanying
     statement of income includes premiums of $nil for the years
     ended Dec. 31, 1994, 1993 and 1992, and decrease in
     liabilities for future policy benefits of $2,538, $3,032 and
     $3,825 related to this agreement for the years ended Dec. 31,
     1994, 1993 and 1992, respectively.

8.   Lines of credit

     The Company has available lines of credit with two banks
     aggregating $30,000 at 40 to 80 basis points over each bank's
     cost of funds.  Outstanding borrowings under these agreements
     were $nil and $1,519 at Dec. 31, 1994 and 1993, respectively.

9.   Derivative financial instruments

     The Company enters into transactions  involving derivative
     financial instruments to manage its exposure to interest rate
     risk, including hedging specific transactions.  The Company
     manages risks associated with these instruments as described
     below.  The Company does not hold derivative instruments for
     trading purposes.

<PAGE>
PAGE 78
9.   Derivative financial instruments (continued)

     Market risk is the possibility that the value of the
     derivative financial instruments will change due to
     fluctuations in a factor from which the instrument derives its
     value, primarily an interest rate.  The Company is not
     impacted by market risk related to derivatives held for non-
     trading purposes beyond that inherent in cash market
     transactions.  Derivatives held for purposes other than
     trading are largely used to manage risk and, therefore, the
     cash flow and income effects of the derivatives are inverse to
     the effects of the underlying transactions. 

     Credit risk is the possibility that the counterparty will not
     fulfill the terms of the contract.  The Company monitors
     credit exposure related to derivative financial instruments
     through established approval procedures, including setting
     concentration limits by counterparty and industry, and
     requiring collateral, where appropriate.  A vast majority of
     the Company's counterparties are rated A or better by Moody's
     and Standard & Poor's.

     The notional or contract amount of a derivative financial
     instrument is generally used to calculate the cash flows that
     are received or paid over the life of the agreement.  Notional
     amounts are not recorded on the balance sheet.  Notional
     amounts far exceed the related credit exposure.

     Credit exposure related to interest rate caps is measured by 
     carrying value of the contracts.
<TABLE><CAPTION>
                                             Notional     Carrying     Fair     Total Credit
         Assets                               Amount      Value       Value     Exposure     
         <S>                                  <C>         <C>         <C>  
         Interest rate caps                   $200,000    $1,389      $828       $1,389
</TABLE>
     The fair values of derivative financial instruments are based
     on market values, dealer quotes or pricing models.  The
     interest rate caps expire on various dates from 1996 to 1997.

     Interest rate caps are used to manage the Company's exposure
     to rising interest rates.  These instruments are used
     primarily to protect the margin between interest rate earned
     on investments and the interest rate credited to related
     annuity contract holders.

     The cost of interest rate caps is amortized to interest
     expense over the life of the contracts and payments received
     as a result of these agreements are recorded as a reduction of
     interest expense when realized.  The amortized cost of
     interest rate cap contracts is included in other investments.
     
<PAGE>
PAGE 79
10.  Fair values of financial instruments

     The Company is required to disclose fair value information for
     most on- and off-balance sheet financial instruments for which
     it is practical to estimate that value.  Certain financial
     instruments such as life insurance obligations, receivables
     and all non-financial instruments, such as deferred
     acquisition costs are excluded from required disclosure.  Off-
     balance sheet intangible assets, such as the value the field
     force, are also excluded.  Management believes the value of
     excluded assets is significant.  The fair value of the
     Company, therefore, cannot be estimated by aggregating the
     amounts presented.
<TABLE><CAPTION>
                                       1994                              1993              
                                    Carrying      Fair                  Carrying      Fair   
        Financial Assets            Value         Value                 Value         Value  
        <S>                         <C>           <C>                   <C>           <C>
        Investments:
        Fixed maturities (Note 2):
          Held to maturity          $686,483      $653,080              $     --      $    --
          Available for sale         455,103       455,103                    --           --
          Investment securities           --            --               1,171,023     1,240,593
        Mortgage loans on
          real estate (Note 2)       164,916       157,085                 123,337       124,030
        Other:
          Equity securities (Note 2)     135           135                     190           190
          Derivative financial
            instruments (Note 9)       1,389           828                   2,050           385
        Cash and
          cash equivalents (Note 1)    5,262         5,262                      --            --
        Assets held in segregated
          asset accounts (Note 1)    506,208       506,208                 380,796       380,796

      Financial Liabilities
         Future policy benefits
           for fixed annuities     1,025,881       991,358               1,003,009       970,169
         Liabilities related to
           segregated asset accounts 474,958       448,665                 357,176       339,122
</TABLE>
     At Dec. 31, 1994 and 1993, the carrying amount and fair value
     of future policy benefits for fixed annuities exclude life
     insurance-related contracts carried at $59,803 and $54,911,
     respectively, and policy loans of $1,683 and $1,085 at Dec.
     31, 1994 and 1993, respectively.  The fair value of these
     benefits is based on the status of the annuities at Dec. 31,
     1994 and 1993.  The fair value of deferred annuities is
     estimated as the carrying amount less any surrender charges
     and related loans.  The fair value for annuities in non-life
     contingent payout status is estimated as the present value of
     projected benefit payments at the rate appropriate for
     contracts issued in 1994 and 1993. 

     At Dec. 31, 1994 and 1993 the fair value of liabilities
     related to segregated asset accounts is estimated as the
     carrying amount less variable insurance contracts carried at
     $31,250 and $23,620, respectively, and surrender charges, if
     applicable. 

<PAGE>
PAGE 80
11.  Statutory insurance accounting practices

     Reconciliations of net income for 1994, 1993 and 1992 and
     stockholder's equity at Dec. 31, 1994 and 1993, as shown in
     the accompanying financial statements, to that determined
     using statutory accounting practices are as follows:
<TABLE><CAPTION>
                                                  1994           1993             1992  
       <S>                                      <C>            <C>             <C>
     Net income, per accompanying
           financial statements                 $23,655        $23,884         $19,962
         Deferred policy acquisition costs      (12,187)       (10,622)        (10,974)
         Adjustments of future policy
           benefit liabilities                   13,741         13,597           9,319
         Deferred federal income taxes           (4,321)          (462)          1,302
         Provision for losses on investments     (1,652)           438          (2,279)
         Separate account gains                     142          2,708           4,234
         Other, net                                 755         (1,182)         (1,757)
         Net income, on basis of
           statutory accounting practices       $20,133        $28,361         $19,807
                                                  =====          =====           =====

                                                                1994             1993   
         Stockholder's equity, per accom-
           panying financial statements                       $171,721       $160,459
         Deferred policy acquisition costs                    (100,078)       (87,891)
         Adjustments of future policy                         
           benefit liabilities                                  33,827         20,086
         Deferred federal income taxes                           2,044         13,018 
         Securities valuation reserve                          (15,939)       (12,780) 
         Adjustments of separate account liabilities            13,557         13,415
         Net unrealized loss on investments                     19,497             --
         Premiums due                                              851            856 
         Deferred revenue liability                                834            895
         Book value adjustment of bonds                             --         (1,918)
         Allowance for losses                                      445          2,097
         Non-admitted assets                                      (503)          (552)
         Interest maintenance reserve                           (2,110)        (2,056)
         Other, net                                                249           (144)
         Stockholder's equity, on basis of
           statutory accounting practices                     $124,395       $105,485 
                                                                ======         ======
/TABLE
<PAGE>
PAGE 81
Report of Independent Auditors

The Board of Directors
IDS Life Insurance Company of New York
         
We have audited the accompanying balance sheets of IDS Life
Insurance Company of New York (a wholly owned subsidiary of IDS
Life Insurance Company) as of December 31, 1994 and 1993, and the
related statements of income and cash flows for each of the three
years in the period ended December 31, 1994.  These financial
statements are the responsibility of the Company's management.  Our
responsibility is to express an opinion on these financial
statements based on our audits.

We conducted our audits in accordance with generally accepted
auditing standards.  Those standards require that we plan and
perform the audit to obtain reasonable assurance about whether the
financial statements are free of material misstatement.  An audit
includes examining, on a test basis, evidence supporting the
amounts and disclosures in the financial statements.  An audit also
includes assessing the accounting principles used and significant
estimates made by management, as well as evaluating the overall
financial statement presentation.  We believe that our audits
provide a reasonable basis for our opinion. 

In our opinion, the financial statements referred to above present
fairly, in all material respects, the financial position of IDS
Life Insurance Company of New York at December 31, 1994 and 1993,
and the results of its operations and its cash flows for each of
the three years in the period ended December 31, 1994, in
conformity with generally accepted accounting principles. 

As discussed in Note 1 to the financial statements, the Company
changed its method of accounting for certain investments in debt
and equity securities in 1994.



Ernst & Young LLP
Minneapolis, Minnesota
February 3, 1995

<PAGE>
PAGE 82
PART C

Item 24.
     Financial Statements and Exhibits

(a)  Financial Statements included in Part B of this Registration
     Statement:

IDS Life of New York Account SBS:

     Statements of Net Assets at Dec. 31, 1994.
     Statements of Operations for year ended Dec. 31, 1994.
     Statements of Changes in Net Assets for years ended 
         Dec. 31, 1994 and 1993.
     Notes to Financial Statements.
     Report of Independent Auditors dated March 17, 1995.

     IDS Life of New York:

     Balance Sheets at Dec. 31, 1994 and Dec. 31, 1993.
     Statements of Income for the years ended Dec. 31, 1994,
         1993 and 1992.
     Statements of Cash Flows for the years ended Dec. 31,
         1994, 1993 and 1992.
     Notes to Financial Statements.
     Report of Independent Auditors dated February 3, 1995.

(b)  Exhibits:

1.1  Copy of Consent in Writing in Lieu of a Meeting of the Board
     of Directors of IDS Life Insurance Company of New York
     establishing Account SLB on October 8, 1991, is filed
     electronically herewith.

1.2  Copy of Consent in Writing in Lieu of Meeting of the Board of
     Directors of IDS Life Insurance Company of New York Account
     SLB establishing three additional subaccounts on October 8,
     1991, is filed electronically herewith.

2.   Not applicable.

3.   Form of Distribution Agreement between IDS Life Insurance
     Company of New York and Shearson Lehman Brothers Inc., the
     principal underwriter, is filed electronically herewith.

4.1  Revised form of Group Flexible Premium Deferred Combination
     Fixed and Variable Annuity Contract (No. 39377 GP) is filed
     electronically herewith.

4.2  Copy of Group Deferred Variable Annuity Certificate (No.
     39377) is filed electronically herewith.

5.1  Revised form of Group Deferred Variable Annuity Application
     (No. 38614 GP) is filed electronically herewith.

5.2  Copy of Variable Annuity Group Enrollment Application (No.
     38614) is filed electronically herewith.
<PAGE>
PAGE 83
6.1  Copy of the Revised Charter of IDS Life of New York, dated
     April 1992, filed electronically as Exhibit 6.1 to Post-
     Effective Amendment No. 4 to Registration Statement No. 33-
     45776/811-6560, is hereby incorporated by reference.

6.2  Copy of the Amended By-Laws of IDS Life of New York, dated May
     1992, filed electronically as Exhibit 6.1 to Post-Effective
     Amendment No. 4 to Registration Statement No. 33-45776/811-
     6560, is hereby incorporated by reference.

7.   Not applicable.

8.   Not applicable.

9.   Opinion of Counsel and consent to its use as to the legality
     of the securities being registered is filed electronically
     herewith.

10.  Consent of Independent Auditors is filed electronically
     herewith.

11.  Financial Statement Schedules and Report of Independent
     Auditors, filed electronically herewith.

     Financial Statement Schedules:

     Report of Independent Auditors dated February 3, 1995.

         Schedule I    -  Consolidated Summary of Investments
                          Other than Investments in Related
                          Parties
         Schedule III  -  Supplementary Insurance Information
         Schedule IV   -  Reinsurance
         Schedule V    -  Valuation and Qualifying Accounts

     All other schedules to the financial statements required by
     Article 7 of Regulation S-X are not required under the related
     instructions or are inapplicable and, therefore, have been
     omitted.

12.  Not applicable.

13.  Copy of schedule for computation of each performance quotation
     is filed electronically herewith.

14.  Financial Data Schedule is filed electronically herewith.

15.  Power of Attorney, dated April 18, 1994, filed electronically
     as Exhibit 14 to Post-Effective Amendment No. 4 to
     Registration Statement No. 33-45776/811-6560, is hereby
     incorporated by reference.

<PAGE>
PAGE 84
Item 25. Directors and Officers of the Depositor (IDS Life
         Insurance Company of New York)
<TABLE><CAPTION>
                                                        Positions and
Name                     Principal Business Address     Offices with Depositor
<S>                      <C>                            <C>
Mario Alaia              20 Madison Avenue Extension    Claims Officer and
                         Albany, NY                       Assistant Secretary

Tracy A. Anderson        IDS Tower 10                   Treasurer and Chief Actuary
                         Minneapolis, MN  55440

Darrell C. Beckstrom     IDS Tower 10                   Underwriting Officer
                         Minneapolis, MN  55440

John C. Boeder           20 Madison Avenue Extension    Director
                         Albany, NY

Michael B. Carlin        20 Madison Avenue Extension    General Counsel and
                         Albany, NY                       Secretary

Roger C. Corea           20 Madison Avenue Extension    Director
                         Albany, NY

Charles A. Cuccinello    20 Madison Avenue Extension    Director
                         Albany, NY

Milton R. Fenster        20 Madison Avenue Extension    Director
                         Albany, NY

Margaret M. Grogan, M.D. Bethlehem Terrace Apts.        Medical Director
                         Slingerland, NY

Lorraine R. Hart         IDS Tower 10                   Investment Officer
                         Minneapolis, MN  55440

Robert A. Hatten         IDS Tower 10                   Director, Vice
                         Minneapolis, MN  55440           President and Chief
                                                          Operating Officer

Richard W. Kling         IDS Tower 10                   Director, Chairman of
                         Minneapolis, MN  55440           the Board and President

Edward Landes            IDS Tower 10                   Director
                         Minneapolis, MN  55440

Janis E. Miller          IDS Tower 10                   Executive Vice President
                         Minneapolis, MN  55440

Michael P. Monaco        World Financial Center         Director
                         New York, NY  

Stephen P. Norman        World Financial Center         Director
                         New York, NY  

<PAGE>
PAGE 85
Kevin E. Palmer          IDS Tower 10                   Reinsurance Actuary
                         Minneapolis, MN  55440

Louise M. Parent         World Financial Center         Director
                         New York, NY

Carl N. Platou           IDS Tower 10                   Director
                         Minneapolis, MN  55440

Gordon H. Ritz           404 WCCO Radio Bldg.           Director
                         Minneapolis, MN  

F. Dale Simmons          IDS Tower 10                   Vice President and
                         Minneapolis, MN  55440           Assistant Treasurer

William A. Stoltzmann    IDS Tower 10                   Counsel and Assistant
                         Minneapolis, MN  55440           Secretary

Michael R. Woodward      20 Madison Avenue Extension    Director
                         Albany, NY
</TABLE>
Item 26.  Persons Controlled by or Under Common Control with the
          Depositor or Registrant

          IDS Life Insurance Company of New York is a wholly owned
          subsidiary of IDS Life Insurance Company which is a
          wholly owned subsidiary of American Express Financial
          Corporation.  American Express Financial Corporation is a
          wholly owned subsidiary of American Express Company
          (American Express).

          The following list includes the names of major
          subsidiaries of American Express.  

                                                  Jurisdiction
Name of Subsidiary                                of Incorporation

I.   Travel Related Services

     American Express Travel Related 
     Services Company, Inc.                       New York

II.  International Banking Services

     American Express Bank Ltd.                   Connecticut

III. Companies engaged in Investors 
     Diversified Financial Services

     American Centurion Life Insurance Company      New York
     American Enterprise Investment Services Inc.   Minnesota
     American Enterprise Life Insurance Company     Indiana
     American Express Financial Advisors Inc.       Delaware
     American Express Financial Corporation         Delaware
     American Express Minnesota Foundation          Minnesota
     American Express Service Corporation           Delaware
     American Express Tax and Business Service Inc. Minnesota
<PAGE>
PAGE 86
Item 26.  Persons Controlled by or Under Common Control with the
          Depositor or Registrant (Continued)

                                                  Jurisdiction
Name of Subsidiary                                of Incorporation

     American Express Trust Company                 Minnesota
     American Partners Life Insurance Company       Arizona
     IDS Advisory Group Inc.                        Minnesota
     IDS Aircraft Services Corporation              Minnesota
     IDS Cable Corporation                          Minnesota
     IDS Cable II Corporation                       Minnesota
     IDS Capital Holdings Inc.                      Minnesota
     IDS Certificate Company                        Delaware
     IDS Deposit Corp.                              Utah
     IDS Fund Management Limited                    U.K.
     IDS Futures Corporation                        Minnesota
     IDS Futures III Corporation                    Minnesota
     IDS Insurance Agency of Alabama Inc.           Alabama
     IDS Insurance Agency of Arkansas Inc.          Arkansas
     IDS Insurance Agency of Massachusetts Inc.     Massachusetts
     IDS Insurance Agency of Mississippi Inc.       Mississippi
     IDS Insurance Agency of Nevada Inc.            Nevada
     IDS Insurance Agency of New Mexico Inc.        New Mexico
     IDS Insurance Agency of North Carolina Inc.    North Carolina
     IDS Insurance Agency of Ohio Inc.              Ohio
     IDS Insurance Agency of Texas Inc.             Texas
     IDS Insurance Agency of Utah Inc.              Utah
     IDS Insurance Agency of Wyoming Inc.           Wyoming
     IDS International, Inc.                        Delaware
     IDS Life Insurance Company                     Minnesota
     IDS Life Insurance Company of New York         New York
     IDS Management Corporation                     Minnesota
     IDS Partnership Services Corporation           Minnesota
     IDS Plan Services of California, Inc.          Minnesota
     IDS Property Casualty Insurance Company        Wisconsin
     IDS Real Estate Services, Inc.                 Delaware
     IDS Realty Corporation                         Minnesota
     IDS Sales Support Inc.                         Minnesota
     IDS Securities Corporation                     Delaware
     American Express Trust Company                 Minnesota
     Investors Syndicate Development Corp.          Nevada

Item 27.  Number of Contractowners  
          On March 31, 1995, there were 145 contract owners of
          qualified contracts.  There were 470 owners of non-
          qualified contracts.

Item 28.  Indemnification

          The By-Laws of the depositor provide that to the extent
          permitted and in the manner prescribed by law, the
          Corporation shall indemnify any person made, or
          threatened to be made,a party to any action, suit or
          proceeding, civil or criminal, by reason of the fact that
          he, his testator or intestate, is or was Director or 
<PAGE>
PAGE 87
          Officer of the Corporation or of any other corporation of
          any type or kind, domestic or foreign, which he served in
          any capacity at the request of the Corporation, against
          judgements, fines, amounts paid in settlement and
          reasonable expenses (which the Corporation may advance),
          including attorneys' fees, actually and necessarily
          incurred as a result of such action, suit or proceeding,
          or any appeal therein.

          The foregoing right of indemnification shall not be
          exclusive of any other right to which any such person may
          be entitled.  Neither the adoption of this provision nor
          any modification or repeal hereof, or of any provision of
          any applicable law shall, unless otherwise required by
          law, enlarge or diminish any right of indemnification of
          a Director or Officer as it existed at the time of
          accrual of the alleged cause of action asserted in the
          threatened or pending action, suit or proceeding in which
          the expenses were incurred or other amount was paid.

          The Board, in its discretion, may authorize the
          Corporation to indemnify any person, other than a
          Director or Officer, for expenses incurred or other
          amounts paid in any civil or criminal action, suit or
          proceeding, to which such person was, or was threatened
          to be, made a party by reason of the fact that he, his
          testator or intestate, is or was an employee or agent of
          the Corporation or of any other  corporation of any type
          or kind, domestic or foreign, which he served in any
          capacity at the request of the Corporation, against
          judgements, fines, amounts paid in settlement and
          reasonable expenses (which the Corporation may advance),
          as a result of such action, suit or proceeding, or any
          appeal therein.

          Insofar as indemnification for liability arising under
          the Securities Act of 1933 may be permitted to director,
          officers and controlling persons of the registrant
          pursuant to the foregoing provisions, or otherwise, the
          registrant has been advised that in the opinion of the
          Securities and Exchange Commission such indemnification
          is against public policy as expressed in the Act and is,
          therefore, unenforceable.  In the event that a claim for
          indemnification against such liabilities (other than the
          payment by the registrant of expenses incurred or paid by
          a director, officer or controlling person of the
          registrant in the successful defense of any action, suit
          or proceeding) is asserted by such director, officer or
          controlling person in connection with the securities
          being registered, the registrant will, unless in the
          opinion of its counsel the matter has been settled by
          controlling precedent, submit to a court of appropriate
          jurisdiction the question whether such indemnification by
          it is against public policy as expressed in the Act and
          will be governed by the final adjudication of such issue.
<PAGE>
PAGE 88
Item 29.  Principal Underwriters.

               (a) Smith Barney Inc. currently acts as principal
          underwriter for various investment companies and various
          series of unit investment trusts.

          Smith Barney Inc. is a wholly owned subsidiary of Smith
          Barney Holdings Inc. ("Holdings") and an indirect wholly-
          owned subsidiary of The Travelers Inc.

               (b) The information required by this Item 29 with
          respect to each director and officer of Smith Barney Inc.
          is incorporated by reference to Schedule A of Form BD
          filed by Smith Barney Inc. pursuant to the Securities
          Exchange Act of 1934.

               (c) Not applicable.

Item 30.  Location of Accounts and Records

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

Item 31.  Management Services

          Not applicable.

Item 32.  Undertakings

          (a),(b)&(c)     These undertakings were filed with Pre-
                          Effective Amendment No. 1 to Registration
                          Statement No. 33-45776/811-6560.

          (d)  Registrant represents that it is relying upon the
               no-action assurance given to the American Council of
               Life Insurance (pub. avail. Nov. 28, 1988). 
               Further, Registrant represents that it has complied
               with the provisions of paragraphs (1) - (4) of that
               no-action letter.
<PAGE>
PAGE 89
                                    SIGNATURES

As required by the Securities Act of 1933 and the Investment
Company Act of 1940, IDS Life Insurance Company of New York, on
behalf of the Registrant, certifies that it meets the requirements
for effectiveness of this Amendment to its Registration Statement
pursuant to Rule 485(b) under the Securities Act of 1933 and has
duly caused this Registration Statement to be signed on its behalf
in the City of Minneapolis, and State of Minnesota, on the 27th day
of April, 1995.

                            IDS LIFE OF NEW YORK ACCOUNT SBS
                                       (Registrant)

                         By IDS Life Insurance Company of New York 
                                          (Sponsor)

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

As required by the Securities Act of 1933, this Registration
Statement has been signed by the following persons in the
capacities indicated on the 27th day of April, 1995.

Signature                               Title

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

/s/ John C. Boeder*                     Director and Chief 
    John C. Boeder                      Operating Officer

/s/ Roger C. Corea*                     Director
    Roger C. Corea

/s/ Charles A. Cuccinello*              Director
    Charles A. Cuccinello

/s/ Milton R. Fenster*                  Director
    Milton R. Fenster

/s/ Edward Landes*                      Director
    Edward Landes

/s/ Michael P. Monaco*                  Director
    Michael P. Monaco

/s/ Stephen P. Norman*                  Director
    Steven P. Norman

/s/ Louise M. Parent*                   Director
    Louise M. Parent

/s/ Carl Platou*                        Director
    Carl Platou

<PAGE>
PAGE 90
Signature                               Title

/s/ Gordon H. Ritz*                     Director
    Gordon H. Ritz

/s/ F. Dale Simmons                     Officer
    F. Dale Simmons

/s/ Michael R. Woodward*                Director
    Michael R. Woodward


* Signed pursuant to Power of Attorney, dated April 18, 1994, filed
electronically as Exhibit 14 to Post-Effective Amendment No. 4 to
Registration Statement No. 33-45776 by:



                                        /s/ Mary Ellyn Minenko     
                                           Mary Ellyn Minenko
<PAGE>
PAGE 91
                    CONTENTS OF POST-EFFECTIVE AMENDMENT NO. 5


This Registration Statement is comprised of the following papers
and documents:

The Cover Page.

Cross-reference sheet.

Part A.

     The prospectus.

Part B.

     Statement of Additional Information.

     Financial Statements.

Part C.

     Other Information.

     The signatures.

<PAGE>
IDS LIFE OF NEW YORK ACCOUNT SBS
Registration No. 33-45776/811-6560

EXHIBIT INDEX

1.1  Copy of Consent in Writing in Lieu of a Meeting of the Board
     of Directors of IDS Life Insurance Company of New York
     establishing Account SLB on October 8, 1991.

1.2    Copy of Consent in Writing in Lieu of a Meeting of the Board
       of Directors of IDS Life Insurance Company of New York
       Account SLB establishing three additional subaccounts on
       October 8, 1991.

3      Form of Distribution Agreement between IDS Life Insurance
       Company of New York and Shearson Lehman Brothers Inc., the
       principal underwriter.

4.1    Revised form of Group Flexible Premium Deferred Combination
       Fixed and Variable Annuity Contract (No. 39377 GP).         
4.2    Copy of Group Deferred Variable Annuity Certificate (No.
       39377).

5.1    Revised form of Group Deferred Variable Annuity Application
       (No. 38614 GP).

5.2    Copy of Variable Annuity Group Enrollment Application (No.
       38614).

9.     Opinion of Counsel.

10.    Consent of Independent Auditors.

11.    Financial Statement Schedules and Report of Independent
       Auditors.

13.    Copy of schedule for computation of each performance
       quotation.

14.    Financial Data Schedules:
         IDS Life of New York Account SBS
         IDS Life Insurance Company of New York

<PAGE>
PAGE 1
TO THE SECRETARY OF
IDS LIFE INSURANCE COMPANY OF NEW YORK

By a Consent in Writing in Lieu of a Meeting received by the
Secretary on October 8, 1991, the Board of Directors of IDS Life
Insurance Company of New York:

     RESOLVED, To establish IDS Life of New York Account SLB,
     comprised of one or more subaccounts, in accordance with
     Section 4240 of the New York Insurance Laws; and

     RESOLVED FURTHER, That the proper officers of the Corporation
     were authorized and directed, as they may deem appropriate
     from time to time and in accordance with applicable laws and
     regulations:  to establish further subaccounts within such
     separate account as they determine to be appropriate and
     change the designation of the separate account to another
     designation.

As President of IDS Life Insurance Company of New York, I hereby
establish, in accordance with the above resolutions and pursuant to
authority granted by the Board of Directors of IDS Life Insurance
Company of New York, the following three additional subaccounts
within the separate account:

     The Total Return subaccount, to invest in shares of the Smith
     Barney Shearson Total Return Portfolio; and

     The International Equity subaccount, to invest in shares of
     the Smith Barney Shearson International Equity Portfolio; and

     The Emerging Growth subaccount, to invest in shares of the
     Smith Barney Shearson Emerging Growth Portfolio.

Further, in accordance with the above resolutions and pursuant to
authority granted by the Board of Directors of IDS Life Insurance
Company of New York, I hereby change the designation of IDS Life of
New York Account SLB to IDS Life of New York Account SBS.

In accordance with the above resolutions and pursuant to authority
granted by the Board of Directors of IDS Life Insurance Company of
New York, the Unit Investment Trust comprised of IDS Life of New
York Account SLB and consisting of seven subaccounts is hereby
reconstituted as IDS Life Account of New York SBS consisting of ten
subaccounts.

/s/ John C. Boeder                  Received by the Secretary
John C. Boeder                      October 14, 1993

                                    /s/ Michael B. Carlin
                                    Michael B. Carlin
<PAGE>
PAGE 1
                      CONSENT IN WRITING IN LIEU
                   OF MEETING OF BOARD OF DIRECTORS


TO THE SECRETARY OF
IDS LIFE INSURANCE COMPANY OF NEW YORK

By this consent in writing in lieu of a meeting of the Board of
Directors of IDS Life Insurance Company of New York, a New York
corporation, we the Directors of said Corporation do hereby consent
to and authorize the adoption of the following resolution to be
effective immediately upon receipt by the Secretary of the
Corporation:

     WHEREAS, This Board of Directors has determined that it is
     desirable for the Corporation to develop a new flexible
     premium deferred combination fixed and variable annuity
     contract to be issued by the Corporation and sold through the
     Shearson Lehman Brothers financial consultants,  Now,
     therefore, be it

     RESOLVED, that IDS Life of New York Account SLB, comprised of
     one or more subaccounts, is hereby established as a separate
     account in accordance with Section 4240, New York Insurance
     Law;

     RESOLVED FURTHER, That the proper officers of the Corporation
     are hereby authorized and directed to establish such
     subaccounts within such separate account as they determine to
     be appropriate;

     RESOLVED FURTHER, That the proper officers of the Corporation
     are hereby authorized and directed, as they may deem
     appropriate from time to time and in accordance with
     applicable laws and regulations to:  establish further any
     subaccounts; change the designation of the separate account to
     another designation; and deregister the separate account;

     RESOLVED FURTHER, That the proper officers of the Corporation
     are hereby authorized and directed to accomplish all filings
     and registrations necessary to carry the foregoing into
     effect.

/s/ Gary A. Beller                  /s/ Edward Landes       
Gary A. Beller                      Edward Landes

/s/ John C. Boeder                  /s/ James A. Mitchell   
John C. Boeder                      James A. Mitchell

/s/ Roger C. Corea                  /s/ M. P. Monaco        
Roger C. Corea                      Michael P. Monaco    

/s/ Charles A. Cuccinello           /s/ Stephen P. Norman   
Charles A. Cuccinello               Stephen P. Norman

/s/ Milton R. Fenster                                       
Milton R. Fenster                   Gordon H. Ritz
<PAGE>
PAGE 2
/s/ D. R. Hubers                                            
David R. Hubers                     Michael F. Weinberg

/s/ R. W. Kling                     /s/ Michael R. Woodward 
Richard W. Kling                    Michael R. Woodward

/s/ Francis W. Ellis


Received by the Secretary

October 8    , 1991
/s/ Michael B. Carlin
Michael B. Carlin

<PAGE>
PAGE 1
VARIABLE ANNUITY CERTIFICATE DISTRIBUTION AGREEMENT

This Agreement entered into as of              , 1992 is between
IDS Life Insurance Company of New York ("IDS Life of New York"), a
New York corporation, and Shearson Lehman Brothers Inc.
("Shearson")1, a Delaware corporation, and is entered into in
consideration of the promises and the mutual agreements herein
contained.

WITNESSETH THAT:

     1.   Appointment.  IDS Life of New York hereby appoints
          Shearson to solicit and procure applications for variable
          annuity certificates to be issued by IDS Life of New York
          to residents of the State of New York.  As used herein,
          the term "certificates" describes interests in a master
          group flexible premium deferred variable annuity
          (Symphony Variable Annuity) issued by IDS Life of New
          York.  This appointment is not exclusive, as IDS Life of
          New York will continue to solicit business through its
          own sales force.  Similarly, Shearson will be under no
          obligation to submit to IDS Life of New York applications
          procured by it through its Financial Consultants for
          variable annuities or certificates that are not governed
          by this Agreement.

     2.   Payment of Commissions.  IDS Life of New York will
          compensate Shearson for its activities hereunder solely
          on the basis of commissions, which will be determined in
          accordance with the SCHEDULE OF COMMISSIONS attached as
          Addendum 2 to this Agreement.  This Schedule may be
          changed from time to time by IDS Life of New York, but
          only with respect to applications taken after the date of
          such change.  Shearson agrees that it will hold IDS Life
          of New york harmless from any claim for commissions or
          other sales compensation by any other person arising out
          of the sale of any certificates under this Agreement.  No
          agreement that Shearson makes with any of its Financial
          Consultants will create any liability on the part of IDS
          Life of New York.  Commissions on certificate sales will
          become payable upon the acceptance of an application and
          the issuance of a certificate.  Except for certificates
          which are to be issued in an exchange under Section 1035
          of the Internal Revenue Code of 1986, as amended
          ("Code"), Shearson will be authorized to deduct from
          certificate purchase payments payable to IDS Life of New
          York the amount of any commission accruing to Shearson
          when and if a certificate is issued.  Commissions on any
          certificate issued pursuant to an exchange under Code
          Section 1035 will be paid monthly to Shearson by IDS Life
          of New York.  If IDS Life of New York declines to issue a
          certificate, it will return the purchase payment to the
          client, will reverse commissions payable to Shearson, and

          1Including its subsidiaries and affiliates (please see
          Addendum 1)
<PAGE>
PAGE 2
          will deduct the reversed commissions from any amount
          thereafter becoming due to Shearson.  If any certificate
          owner exercises a right under a "free look" option and
          cancels the certificate, IDS Life of New York will deduct
          any commission already paid with respect to such
          certificate from any amounts thereafter becoming due to
          Shearson.

     3.   Certificate Application and Issuance.  Each certificate
          application taken by a Shearson Financial Consultant will
          be promptly forwarded to Shearson, together with the
          purchase payment and any required forms.  Shearson will
          conduct a review to determine the suitability of the sale
          and that the sale follows established IDS Life of New
          York procedures regarding forms, applications and other
          such matters of administration which have been submitted
          in writing by IDS Life of New York to Shearson prior to
          appointing Shearson Financial Consultants to solicit
          applications.  After Shearson has conducted its review,
          it will forward all relevant material to IDS Life of New
          York's home office, whereupon IDS Life of New York will
          conduct its own review of the application.  IDS Life of
          New York will be under no obligation to accept any
          application which, in its sole discretion with or without
          reason, it determines to be unacceptable to it.  Upon
          issuance, each certificate sold through Shearson will be
          mailed directly from IDS Life of New York to Shearson for
          personal delivery to the certificate owner by the
          Shearson Financial Consultant.

     4.   Representations.  Shearson agrees that its Financial
          Consultants will fully explain the terms and conditions
          of the variable annuity and related certificates and will
          not make untrue statements, interpretations or
          misrepresentations, nor omit or evade material facts
          concerning the variable annuity and certificates which
          prospects should know.  Shearson is not authorized and is
          expressly forbidden to incur any indebtedness or
          liability or make, alter or discharge any certificate,
          waive any forfeiture or make any guarantee on behalf of
          IDS Life of New York.  Shearson will not use any sales
          literature or other written materials unless they have
          been approved in writing by IDS Life of New York.  IDS
          Life of New York will furnish to Shearson reasonable
          supplies of sales literature which it has developed after
          consultation with Shearson.

          IDS Life of New York certifies that all advertising,
          certificates, brochures and other materials developed by
          it and delivered to Shearson:

               i)    have been read and approved by or on behalf of
               IDS Life of New York;

               ii)   are in conformity with the terms and conditions
               of the variable annuity and related certificates;

<PAGE>
PAGE 3
               iii)  shall meet the requirements of all federal,
               state and appropriate regulatory authorities; and

               iv)   IDS Life of New York undertakes responsibility
               for same.

     5.   Licensing and Indemnification.  No person associated with
          Shearson will offer or sell and IDS Life of New York
          certificate unless that person is duly licensed as a
          variable annuity agent for IDS Life of New York under
          applicable state law.  Qualification and licensing will
          be the sole responsibility of Shearson, but IDS Life of
          New York will make such appointments as requested by
          Shearson and otherwise fully cooperate with Shearson. 
          Shearson assumes full responsibility for the supervision
          of its associated persons and all of their activities
          relating to the IDS Life of New York variable annuity and
          related certificates.  Shearson shall not bear any
          liability for solicitation of applications and the
          results therefrom in any jurisdiction if IDS Life of New
          York shall not have provided appropriate notification,
          prior to any such solicitation, of any lack of corporate
          authority, policy approval or limitation of availability. 
          IDS Life of New York shall indemnify and hold Shearson
          harmless from and against any and all claims, liabilities
          and expenses arising therefrom.  Further, Shearson agrees
          to indemnify and hold IDS Life of New York, its officers,
          directors, employees or agents harmless from any and all
          costs, expenses, causes of actions, loss or damages or
          liabilities resulting from negligent, fraudulent, or
          unauthorized acts or omissions by Shearson, its
          employees, contractors or agents.  IDS Life of New York
          shall indemnify and hold Shearson, its officers,
          directors, employees and agents, harmless from any and
          all costs, expenses, causes of action, loss or damages or
          liabilities resulting from negligent, fraudulent, or
          unauthorized acts of omissions by IDS Life of New York,
          its employees, contractors or agents, including without
          limitation, the term of the variable annuity and related
          certificates, breach of the terms of any certificate sold
          hereunder, any failure of the variable annuity and
          related certificates to conform with any written
          description furnished by IDS Life of New York to
          Shearson's agents, applicants or prospective applicants,
          or from any change in applicable law or regulations
          retroactively affecting the issued variable annuity and
          certificates or rendering any such written description
          incomplete or misleading, or from any failure of IDS Life
          of New York to notify Shearson in writing immediately of
          changes in existing government insurance regulations. 
          Shearson and IDS Life of New York agree to notify the
          other party if any legal action is brought against either
          party hereto, or both parties jointly, by reason of any
          alleged act, fault or failure of either Shearson or IDS
          Life of New York under this Agreement.
<PAGE>
PAGE 4
     6.   In-force Certificates.  Shearson will use its best
          efforts, both while this Agreement is in effect and
          following its termination, to continue in force all IDS
          Life of New York certificates placed in force through
          Shearson while this Agreement was in effect; provided,
          however, that in any given case a Shearson Financial
          Consultant will be free to recommend a contract exchange
          to his or her client if it is determined in good faith
          that the exchange would clearly be in the best interests
          of the client.

     7.   Termination of Agreement.  This Agreement may be
          terminated at any time by mutual agreement of the parties
          hereto, or by thirty (30) days' written notice given by
          either party to the other.

     8.   Advertising or Publicity.  No party hereunder shall use
          the name of any other party hereunder in any advertising
          or publicity release without securing the prior written
          approval of the applicable party.

     9.   Confidential Information.  During the term of this
          Agreement and for a period ten (10) years from the date
          of its termination, IDS Life of New York will regard and
          preserve as confidential all information related to the
          business of Shearson, its parent company and its
          subsidiaries and affiliated companies and its or their
          clients that may be obtained from any source as a result
          of this Agreement.  IDS Life of New York will not,
          without obtaining Shearson's written consent, disclose to
          any person, firm or enterprise, or use for its benefit,
          any information relating to the pricing, methods,
          processes, financial data, lists, apparatus, statistics,
          programs, research, development or related information of
          Shearson, its parent company or its subsidiaries or
          affiliated companies or its or their clients, concerning
          past, present or future business activities of said
          entities.

IN WITNESS WHEREOF, the parties have caused this Agreement to be
executed as of the      day of         , 1992.


SHEARSON LEHMAN BROTHERS INC.

By:                         

Its:                        

IDS LIFE INSURANCE COMPANY OF NEW YORK

By:                         

Its:                        

<PAGE>
PAGE 1
GROUP DEFERRED ANNUITY CONTRACT

- - Flexible purchase payments
- - Optional fixed dollar or variable accumulation values
- - Fixed dollar annuity payments
- - Annuity payments to begin on the retirement date.
- - This contract is nonparticipating.  Dividends are not payable.

Contractholder:           ABC Trust Company

Contract Number:          39377GP-1

Contract Date:            November 1, 1991

IDS Life Insurance Company of New York, herein called the Company,
will pay the benefits provided by this contract in accordance with
and subject to all provisions of this contract.

We issue this contract in consideration of the application of the
contractholder.

Signed for and issued by IDS Life Insurance Company of New York,
Albany, New York, as of the contract date shown above.

ACCUMULATION VALUES, WHEN BASED ON THE INVESTMENT RESULTS OF THE
SEPARATE ACCOUNT, ARE VARIABLE AND NOT GUARANTEED AS TO FIXED
DOLLAR AMOUNT.

NOTICE OF CONTRACTHOLDER'S RIGHT TO EXAMINE CONTRACT FOR 20 DAYS
If for any reason the contractholder is not satisfied with this
contract, the contractholder may cancel it by returning it to us or
our agent within 20 days after receiving it.  We will then cancel
the contract.  We will refund all payments made.  The contract will
be considered void from its start.

NOTICE OF CERTIFICATE OWNERS' RIGHT TO EXAMINE CERTIFICATES ISSUED
UNDER THIS CONTRACT FOR 20 DAYS
If for any reason an owner is not satisfied with a certificate
issued under this contract, the owner may cancel it by returning it
to us or our agent within 20 days after receiving the certificate. 
We will then cancel the certificate.  We will refund all payments
the owner has paid.  The certificate will be considered void from
the start.

President SPECIMEN


Secretary SPECIMEN<PAGE>
PAGE 2
GUIDE TO CONTRACT PROVISIONS

Definitions
Important words and meanings/Page 3

General Provisions
Entire contract; Contract modification; Incontestability; Benefits
based on incorrect data; State laws, Reports to owner; Evidence of
survival; Protection of proceeds; Payments by us; Voting
rights/Page 5

Group Contractholder, Owner and Beneficiary
Group contractholder, Owner rights; Change of ownership;
Beneficiary; Change of Beneficiary; Assignment/Page 7

Payments to Beneficiary
Describes options and amounts payable upon death/Page 8

Purchase Payments
Certificate purchase payments amounts; Payment limits; Allocations
of purchase payments/Page 10

Certificate Value
Describes the fixed and variable certificate values; Interest to be
credited; Certificate administrative charge; Premium taxes;
Transfers of certificate values/Page 12

Fixed and Variable Accounts
Describes the fixed account; Describes the variable subaccounts,
accumulation units and values; Net investment factor; Mortality and
expense risk charge; Variable account administrative charge/Page 14

Surrender Provisions
Surrender of the certificate for the cash surrender value; Rules
for surrender; TSA distribution restrictions; Premature
distribution penalty tax; Tax-qualified minimum distribution
requirements/Page 16

Annuity Provisions
When annuity payments begin; Different ways to receive annuity
payments; Determination of payment amounts/Page 20

Tables of Settlement Rates
Tables showing guaranteed fixed dollar annuity payments for the
various payment plans/Page 22<PAGE>
PAGE 3
DEFINITIONS

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

annuitant
The person on whose life monthly annuity payments depend.

owner
The owner of a certificate.  The owner may be someone other than
the annuitant.  The owner is shown in the enrollment application
unless the owner has been changed as provided in this contract.

we, us, our
IDS Life Insurance Company of New York.

accumulation unit
An accumulation unit is an accounting unit.  It is used to
calculate the certificate value prior to settlement.

certificate date
It is the date from which certificate anniversaries, certificate
years, and certificate months are determined.  The certificate date
is shown under Certificate Data, in the certificate.

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

payment year
Each certificate year in which an owner makes a purchase payment
and each succeeding year measured from the end of the certificate
year during which such payment is made.  For example, with an
initial purchase payment of $15,000 and an additional purchase
payment of $10,000 during the 4th certificate year, the 6th
certificate year will be:

     -    the 6th payment year with respect to the initial $15,000
          purchase payment; and
     -    the 3rd payment year with respect to the additional
          $10,000 purchase payment

certificate value
The sum of the: (1) Fixed Account Certificate Value; and the (2)
Variable Account Certificate Value.

retirement date
The date shown under Certificate Data, in the certificate, on which
annuity payments are to begin.  This date may be changed as
provided in this contract.

settlement
The application of the accumulation value of a certificate to
provide fixed dollar annuity payments.

valuation date
A valuation date is each day the New York Stock Exchange is open
for trading.<PAGE>
PAGE 4
valuation period
A valuation period is the interval of time commencing at the close
of business on each valuation date and ending at the close of
business on the next valuation date.

fixed account
The fixed account is made up of all our assets other than those in
any separate account.

variable account
The variable account is a separate investment account of ours.  It
consists of several subaccounts.  Each subaccount is named under
Certificate Data, in the certificate.

fixed annuity
A fixed annuity is an annuity with payments which are guaranteed by
us as to dollar amount during the annuity payment period.

written request
A request in writing signed by the owner and delivered to us at our
hone office.

Code
The Internal Revenue Code of 1986, as amended, and all related laws
and regulations which are in effect during the term of this
contract.

tax-qualified certificate
A certificate used in or under a retirement plan or program that is
intended to qualify under Section 401, 403 or 408 of the Code. 
These include, but are not limited to, TSA certificates, IRA
certificates and SEP/IRA certificates defined below.

TSA certificate
A Tax-Sheltered Annuity as described in Section 403(b) of the Code. 
A TSA is a tax-qualified certificate as defined above.

IRA certificate
A certificate used in or under a retirement plan or program that is
intended to qualify under Section 408(b) of the Code.  An IRA
certificate is a tax-qualified certificate as defined above.

SEP/IRA certificate
A Simplified Employee Pension (SEP/IRA) certificate.  It is used in
or under a retirement plan or program that is intended to qualify
under Section 408(k) of the Code.  An SEP/IRA is an IRA with
special features and requirements.  A SEP/IRA certificate is a tax-
qualified certificate as defined above.

non-qualified certificate
A certificate used mainly for retirement purposes under a plan or
program that is not intended to qualify under Section 401, 403 or
408 of the Code.<PAGE>
PAGE 5
GENERAL PROVISIONS

Entire Contract
The entire contract consists of: this group contract; the
application of the group contractholder, which is attached to the
group contract; and the enrollment applications.

No one except one of our corporate officers (President, Vice
President, Secretary or Assistant Secretary) can change or waive
any of our rights or requirements under this contract.  That person
must do so in writing.  None of our representatives or other
persons has the authority to change or waive any of our rights or
requirements under this contract.

Contract Modification
We will modify this contract if needed to:

1.   qualify certificates issued under this contract as annuity
     certificates under Section 72 of the Code and all related laws
     and regulations which are in effect during the term of this
     contract; and

2.   if certificates issued under this contract are purchased as
     tax-qualified certificates under the applicable Section 401,
     403 or 408 of the Code and all related laws and regulations
     which are in effect during the term of this contract.

We will obtain the approval of the State of New York and any other
regulatory authority for the modification.  We will provide the
contractholder and the existing certificate owners with notice and
copy of any such modifications, approved for use in the state of
jurisdiction, and an explanation of their effect upon the contract. 
An existing certificate owner may reject the modifications by
writing to us.

Incontestable
Certificates issued under this contract are incontestable from
their issue dates.

Are the certificates on a sex distinct or a unisex basis?
Nonqualified and IRA certificates are on a sex distinct basis. 
SEP/IRA, TSA and other tax-qualified certificates are on a unisex
basis.

Benefits Based on Incorrect Data
For tax-qualified certificates, except for IRA certificates:  If
the amount of benefits is determined by data as to a person's age
that is incorrect, benefits will be recalculated on the basis of
the correct data.  Any underpayments made by us will immediately be
paid in a single sum with an interest credit of 6% per annum.  Any
overpayments made by us will be subtracted from the future payments
together with an interest credit of 6% per annum.

For non-qualified certificates and IRA certificates:  If the amount
of benefits is determined by data as to a person's age or sex that
is incorrect, benefits will be recalculated on the basis of the
correct data.  Any underpayments made by us will immediately be<PAGE>
PAGE 6
paid in a single sum with an interest credit of 6% per annum.  Any
overpayments made by us will be subtracted from the future payments
together with an interest credit of 6% per annum.

State Laws
This contract is governed by the law of the state in which it is
delivered to the contractholder.  The values and benefits of the
certificates are at least equal to those required by such state and
by the state in which the certificate is delivered to the
certificate owner.  Any paid up annuity, cash surrender or death
benefit is not less than the minimum benefit required by any
statute of the state in which the contract is delivered and by any
statute of the state in which the certificate is delivered to the
certificate owner.

Reports to Owner
At least once a year we will send each owner a statement showing
the certificate value and the certificate cash surrender value. 
The statement will be based on the laws and regulations of the
state in which the certificate is delivered to the certificate
owner and of any other applicable laws or regulations that apply to
certificates of this type.

Evidence of Survival
Where any payments under a certificate depend upon the recipient or
annuitant being alive on a certain date, proof that such condition
has been met may be required by us.  Such proof may be required
prior to making the payments.

Protection of Proceeds
Payments under any certificate are not assignable by any
beneficiary prior to the time they are due.  To the extent allowed
by law, payments are not subject to the claims of creditors or
legal process.

Payments by Us
All sums payable by us are payable at our home office.  Any payment
of a variable annuity or surrender based upon the variable
certificate value shall be payable only from the variable accounts.

Voting Rights
So long as federal law requires, the owner may have the right to
vote at meetings of the Variable Shareholders.  If the owners have
voting rights we will send a notice to them telling the time and
place of a meeting.  The notice will also explain matters to be
voted upon and how many votes the owner gets.<PAGE>
PAGE 7
CONTRACTHOLDER, OWNER AND BENEFICIARY

Group Contractholder
The group contractholder is shown on the cover page of this
contract.  The contract provides for a successor contractholder. 
In the event the contractholder should merge with another
corporation, the new corporation would be the group contractholder.

Certificate Owner Rights
As long as the annuitant is living and unless otherwise provided in
this contract, the owner will have the sole and absolute power to
receive and enjoy all rights under the certificate.  The owner's
entire interest is non-forfeitable.

For tax-qualified certificates owned by tax-qualified trusts or
tax-qualified custodial accounts, the trustees or custodian or
successor trustees or successor custodian properly named by the
trust or custodial agreement may exercise all rights and privileges
provided in this contract or allowed by us.

Change of Ownership
For tax-qualified certificates, the right to change the ownership
is restricted.  The certificate may not be: sold; assigned;
transferred; discounted or pledged as collateral for a loan or as
security for the performance of an obligation; or for any other
purpose to any person other than as may be required or permitted
under Sections 401, 403 or 408 of the Code, or under any other
applicable section of the Code.  However, if the certificate is
owned by a trustee of a tax-qualified trust or the custodial of a
tax-qualified custodial account, such trustee or custodian may
transfer ownership of the certificate to the annuitant or to a
qualified successor trustee or custodian.

Also, interests in IRA and SEP/IRA certificates may be transferred
to the owner's former spouse, if any, under a divorce decree or a
written instrument incidental to such divorce.

For non-qualified certificates, the owner may change the ownership.

Any change of ownership as provided above must be made by written
request on a form approved by us.  The change must be made while
the annuitant is living.  Once the change is received by us, it
will take effect as of the date of the request, subject to any
action or payment made by us before the receipt.

Beneficiary
Beneficiaries are those the owner has named in the enrollment
application or later changed as provided below, to receive the
benefits of the certificate if the owner or the annuitant dies
while the certificate is in force.

Only those beneficiaries who are living when death benefits become
payable may share in the benefits, if any.  If no beneficiary is
then living, we will pay the benefits to the owner, if living;
otherwise to the owner's estate.

Change of Beneficiary
The owner may change the beneficiary anytime while the annuitant is
living.  This must be done by satisfactory written request to us. <PAGE>
PAGE 8
Once the change is received by us, it will take effect as of the
date of the owner's request, subject to any action taken or payment
made by us before the receipt.

Assignment
Tax-qualified certificates may not be assigned as collateral.

The owner may assign non-qualified certificates or any interest in
them.  The annuitant must be living.  The owner's interest and the
interest of any beneficiary is subject to the interest of the
assignee.  An assignment is not a change of ownership and an
assignee is not an owner as these terms are used in this contract. 
Any amounts payable to the assignee will be paid in a single sum.

A copy of any assignment must be submitted to us at our home
office.  Any assignment is subject to any action taken or payment
made by us before the assignment was received at our home office. 
We are not responsible for the validity of any assignment.

PAYMENTS TO BENEFICIARY

Death Benefits Before the Retirement Date
If the owner or the annuitant dies before the fifth certificate
anniversary while the certificate is in force, we will pay the
beneficiary the greater of the certificate value or the purchase
payments paid less any amounts surrendered.

On or after the initial fifth certificate anniversary, and each
subsequent fifth certificate anniversary thereafter, we will pay
the beneficiary the greater of the certificate value or a minimum
guaranteed death benefit which equals:

1.   the death benefit calculated as of the previous fifth
     certificate anniversary; plus
2.   any purchase payments made since the previous fifth
     certificate anniversary; minus
3.   any surrenders since the previous fifth certificate
     anniversary.

The above amount will be paid in a lump sum upon the receipt of due
proof of death of the owner or annuitant, whichever first occurs. 
The beneficiary may elect to receive payment anytime within 5 years
after the date of death.

In lieu of a lump sum, payment may be made under an Annuity Payment
Plan, provided:

1.   The beneficiary elects the plan within 60 days after we
     receive proof of death; and
2.   The plan provides payments over a period which does not exceed
     the life or life expectancy of the beneficiary; and
3.   For non-qualified certificates:
     Payments begin no later than one year after the date of death;
     and
4.   For tax qualified certificates;
     (a)  Payments begin no later than one year after the date of
          death, in the case of a non-spouse beneficiary; or<PAGE>
PAGE 9
     (b)  Payments begin no later than the date on which the
          annuitant would have attained age 70 1/2 or one year
          after the date of death, in the case of a spousal
          beneficiary; and
     (c)  Amounts are calculated in accordance with the Code.

In this event, the reference to "annuitant" in the Annuity Payment
Plans section shall apply to the beneficiary.

Required Distribution at Annuitant's Death Prior to the Retirement
Date
The Code requires a distribution on the death of the annuitant if a
certificate is owned by a corporation or other non-individual.  If
we receive due proof that the annuitant died while a certificate
was in force before settlement, we will pay to the beneficiary the
death benefit described in Death Benefits Before the Retirement
Date.  The death benefit will be determined as of the date on which
due proof of death is received at our home office.

Refer to the other provisions of the Payments to Beneficiary
section.  They explain the distribution methods and timing the
beneficiary may elect.  A spouse beneficiary, if eligible as
explained in the provision below, may elect spousal continuation.

Spouse's Option to Continue Certificate
For non-qualified certificates:  If the owner dies prior to the
retirement date, and the owner's spouse is the sole beneficiary of
the certificate, the spouse may forego receipt of the death benefit
and instead keep the certificate in force as its owner and
annuitant.  The election by the spouse must be made within 60 days
after we receive due proof of death.  Additional purchase payments
may be made to the annuity.

For IRA and SEP/IRA certificates:  If the owner dies prior to the
retirement date, and the owner's spouse is the sole beneficiary of
the certificate, the spouse may forego receipt of the death benefit
and instead keep the certificate in force as its owner and
annuitant.  The election by the spouse must be made within 60 days
after we receive due proof of death.  Additional purchase payments
may be made to the IRA annuity.  The spouse may defer beginning
annuity payments until the spouse attains age 70 1/2 or such other
date as provided in the Code.  Any annuity payment plan later
elected must provide for amounts calculated in accordance with the
Code.  The applicable IRA or SEP/IRA limitations of the original
certificate will continue to apply to the certificate with the
spousal owner and annuitant.

For tax-qualified certificates other than IRAs and SEP/IRAs:
If the owner dies prior to the retirement date, and the annuitant's
spouse is the sole beneficiary of the certificate, the spouse may
forego receipt of the death benefit and instead keep the
certificate in force as its owner and annuitant.  If the owner is a
non-individual, such as a Section 401 retirement plan, if the
annuitant's spouse is the sole beneficiary of the certificate, the
spouse may forgo receipt of the death benefit and instead keep the
certificate in force as its owner and annuitant.  The election by
the spouse must be made within 60 days after we receive due proof
of death.  Additional purchase payments may not be made to the<PAGE>
PAGE 10
annuity.  The spouse may defer beginning annuity payments until the
annuitant would have attained age 70 1/2 or such other date as
provided in the Code.  Any annuity payment plan later elected must
provide for amounts calculated in accordance with the Code.  The
applicable tax-qualified limitations of the original certificate
will continue to apply to the certificate with the spousal owner
and annuitant.

Death After the Retirement Date
If annuity payments are being made under Plans B, C or E (see
Annuity Payment Plans), any remaining guaranteed payments will be
continued to the beneficiary, if living; if not, the owner's
estate.

PURCHASE PAYMENTS

Purchase Payments
Purchase payments are the payments an owner makes for a certificate
and the benefits it provides.  Purchase payments for a certificate
consist of the initial purchase payment and any additional optional
purchase payments the owner makes.  Purchase payments must be paid
to us at our home office or to an authorized agent.  If requested,
we will give the owner a receipt for the purchase payment.  Upon
payment to us, purchase payments become our property.

Net purchase payments are that part of the owner's purchase payment
applied to the certificate value.  A net purchase payment is equal
to the purchase payment less any applicable premium tax charge.

Additional Purchase Payments
Additional purchase payments may be made to a certificate until the
earlier of:

1.   the date the certificate terminates by surrender or otherwise;
     or
2.   the date on which annuity payments begin for a certificate.

Additional purchase payments are subject to the Payment Limits
Provision below.

Payment Limits Provision
Maximum Purchase Payments - The maximum total purchase payments for
a certificate in the first and later certificate years is
$1,000,000.  We have the right to increase the maximums on a
uniform basis for all certificate holders in a class.

Additional Purchase Payments - The owner may make additional
purchase payments of at least $500 for nonqualified certificates
and at least $50 for tax-qualified certificates.

IRA certificate purchase payments must be:

o    Active IRA contributions.  Active IRA contributions are
     described in Code Sections 408(b)(2) and 219 and generally may
     not exceed $2,000 for any taxable year except for the
     permissible $2,250 contribution of an individual with a non-
     working spouse; or<PAGE>
PAGE 11
o    Rollover or transfer IRA contributions of accumulated past
     active IRA contributions.  Rollover IRA contributions are
     described in Code Section 408(d)(3); or
o    Rollover IRA contributions of distributions from the owner's
     employer's tax-qualified retirement plan.  Employer retirement
     plan rollovers are described in Code Sections 402(a)(5),
     402(a)(7), 403(a)(4) or 403(b)(8).

SEP/IRA certificate purchase payments must be:

o    Current SEP/IRA contributions.  SEP/IRA contributions are
     described in Code Sections 408(k) and 219.  SEP/IRA
     contributions must be made by an employer from employer
     monies.  Generally employer SEP/IRA contributions for any
     taxable year may not exceed the lesser of 15% of the owner's
     compensation or $30,000 (as indexed); or
o    Rollover or transfer SEP/IRA contributions of accumulated past
     SEP/IRA contributions.  Rollover contributions are described
     in Code Section 408(d)(3).

TRA certificate purchase payments must be:

o    Current TSA contributions.  TSA contribution limits are
     described in Code Sections 403(b)(2), 415(c) and 402(g).  TSA
     contributions must be made by an employer from employer
     monies.  Generally employer contributions to all defined
     contribution plans, including TSAs, for any taxable year may
     not exceed 25% of the owner's compensation or $30,000 (as
     indexed).  The employer and/or personal tax adviser should be
     consulted for detailed TSA contribution limits; or
o    Rollover or transfer TSA contributions of accumulated past TSA
     contributions.  TSA rollovers are described in Code Section
     403(b)(8).

Tax-qualified certificate purchase payments must be:

o    Current Section 401 retirement plan contributions.
     Contribution limits are as described in the specific
     retirement plan documents; or
o    Transfers of accumulated past Section 401 retirement plan
     contributions.

All purchase payments must be made in cash.  If the owner dies
before the entire interest in the certificate has been distributed,
and the beneficiary is other than a surviving spouse, no additional
purchase payments will be accepted from the beneficiary for the
certificate.

Allocation of Purchase Payments
The owner instructs us on how to allocate purchase payments among
the fixed account and the variable subaccounts.  The choice for the
fixed account and each variable subaccount may be made in any whole
percent from 0% to 100%.  For nonqualified certificates, no
allocation may be made that would result in a fixed account value
or a variable subaccount value of less than $500.  The owner's
allocation instructions as of the certificate date are shown under
Certificate Data, in the certificate.
<PAGE>
PAGE 12
By written request, or by another method agreed to by us, the owner
may change the choice of accounts or percentages.

The first net purchase payment will be allocated as of the date the
purchase payment is received at our home office.  Net purchase
payments after the first will be allocated as of the end of the
valuation period during which we receive the payment at our home
office.

CERTIFICATE VALUE

Certificate Value
The certificate value of a certificate at any time is the sum of:

1.   the Fixed Account Certificate Value; and
2.   the Variable Account Certificate Value.

If:

1.   part or all of the certificate value is surrendered; or
2.   charges described herein are made against the certificate
     value;

then a number of accumulation units from the variable subaccounts
and an amount from the fixed account will be deducted to equal such
amount.  For surrenders, deductions will be made from the fixed
account or variable subaccounts that the owner specifies. 
Otherwise, the number of units from the variable subaccounts and
the amount from the fixed account will be deducted in the same
proportion that the owner's interest in each bears to the total
certificate value.

Fixed Account Certificate Value
The fixed account certificate value at any time will be:

1.   the sum of all amounts credited to the fixed account under the
     certificate; less
2.   any amounts deducted for charges or surrenders.

Interest to be Credited
We will credit interest to the fixed account certificate value. 
Interest will begin to accrue on the date the purchase payments are
received in our home office.  Such interest will be credited at
rates we determine from time to time.  However, we guarantee that
the rate will not be less than 4% per year compounded annually.

Variable Account Certificate Value
The variable account certificate value at any time will be:

1.   the sum of the value of all variable subaccount accumulation
     units under the certificate resulting from purchase payments
     so allocated, or transfers among the variable and fixed
     accounts; less
2.   any units deducted for charges or surrenders.

Certificate Administrative Charge
We charge a fee for establishing and maintaining our records for
certificates.  The charge is $30 per certificate per year and is
deducted from the certificate value at the end of each certificate<PAGE>
PAGE 13
year.  The charge deducted will be prorated among the variable
subaccounts and the fixed account in the same proportion the
owner's interest in each bears to the total certificate value.

If an owner fully surrenders a certificate, we deduct a certificate
administrative charge that is prorated based on the number of days
from the last certificate anniversary to the date of full
surrender.  The charge does not apply after the settlement of a
certificate.

Premium Tax Charges
A charge will be made by us against the certificate value of a
certificate for any applicable premium taxes not previously
deducted.

Transfers of Certificate Values
Owners may make transfers of certificate values while certificates
are in force prior to the settlement dates as outlined below:

1.   An owner may transfer all or a part of the values held in one
     or more of the variable subaccounts to another one or more of
     the variable subaccounts.

2.   An owner may transfer all or a part of the values held in one
     or more of the variable subaccounts to or from the fixed
     account subject to these restrictions:

     (a)  Certificate values may be transferred from the fixed
          account to a variable subaccount, or vice versa, up to
          six times per certificate year subject to item (b) below.

     (b)  If a transfer is made from the fixed account to a
          variable subaccount, no transfer from any variable
          subaccount to the fixed account may be made for six
          months from the transfer date.

The owner may make a transfer by written request.  There is no fee
or charge for these transfers.  However, the minimum transfer
amount is $500, or if less, the entire value in the subaccount or
in the fixed account from which the transfer is being made.

FIXED AND VARIABLE ACCOUNTS

The Fixed Account
The fixed account is our general account.  It is made up of all our
assets other than

1.   those in the variable account; and
2.   those in any other segregated asset account.

The Variable Account
The variable account is a separate investment account of ours.  If
consists of several subaccounts.  We have allocated a part of our
assets for this and certain other contracts to the variable
account.  Such assets remain our property.  However, they may not
be charged with the liabilities from any other business in which we
may take part.
<PAGE>
PAGE 14
Investments of the Variable Account
Certificate purchase payments applied to the variable account will
be allocated as specified by the owner.  Each variable subaccount
will buy, at net asset value, shares of the Portfolio shown for
that subaccount under Certificate Data, in the certificate, or as
later added or changed.

Valuation of Assets
Portfolio shares in the variable subaccounts will be valued at
their net asset value.

Variable Account Accumulation Units
The number of accumulation units for each of the variable
subaccounts in a certificate is found by dividing

1.   the net amount allocated to the certificate subaccount; by
2.   the accumulation unit value for the subaccount for the
     valuation period during which we received the certificate
     purchase payment.

and subtracting the number of certificate accumulation units
resulting from:

1.   transfers from the certificate subaccount; and
2.   surrenders (including surrender charges) from the certificate
     subaccount; and
3.   certificate administrative charge deductions from the
     certificate subaccount.

The number of accumulation units added or subtracted for each of
the above transactions is found by dividing:

1.   the number allocated to or deducted from the certificate's
     subaccount; by
2.   the accumulation unit value for the certificate's subaccount
     for the respective valuation period during which we received
     the purchase payment or transfer value, or during which we
     deducted transfers, surrenders, surrender charges or
     certificate administrative charges.

Variable Account Accumulation Unit Value
The value of an accumulation unit for each of the variable
subaccounts was set at $1 when the first Portfolio shares were
bought.  The value for any later valuation period is found as
follows:

     The accumulation unit value for each variable subaccount for
     the last prior valuation period is multiplied by the net
     investment factor for the same subaccount for the next
     following valuation period.  The result is the accumulation
     unit value.  The value of an accumulation unit may increase or
     decrease from one valuation period to the next.

The net investment factor is an index applied to measure the
investment performance of a variable subaccount from one valuation
period to the next.  The net investment factor may be greater or
less than one; therefore, the value of an accumulation unit may
increase or decrease.
<PAGE>
PAGE 15
The net investment factor for any such subaccount for any valuation
period is determined by: dividing (1) by (2) and subtracting (3)
and (4) from the result.  This is done where:

1.   is the sum of
     a.   the net asset value per share of the Portfolio held in
          the variable 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 variable
          subaccount, if the "ex-dividend" date occurs during the
          current valuation period.

2.   is the net asset value per share of the Portfolio held in the
     variable subaccount, determined at the end of the last prior
     valuation period.

3.   is a factor representing the mortality and expense risk
     charge.

4.   is a factor representing the variable account administrative
     charge.

Mortality and Expense Risk Charge
In calculating accumulation unit values we will deduct a mortality
and expense risk charge from the variable subaccounts equal, on an
annual basis, to 1.25% of the daily net asset value.  This
deduction is made to compensate us for assuming the mortality and
expense risks under certificates of this type.  The deduction will
be:

1.   made from each variable subaccount; and
2.   computed on a daily basis.

Variable Account Administrative Charge
In calculating accumulation unit values we will deduct a variable
account administrative charge from the variable subaccounts equal,
on an annual basis, to 0.25% of the daily net asset value.  This
deduction is made to compensate us for certain administrative and
operating expenses for certificates of this type.  The deduction
will be:

1.   made from each variable subaccount; and
2.   computed on a daily basis.

SURRENDER PROVISIONS

Surrender
By written request and subject to the roles below the owner may:

1.   surrender the certificate for the total surrender value; or
2.   partially surrender the certificate for a part of the
     surrender value.

Surrender Value
The surrender value at any time will be:
<PAGE>
PAGE 16
1.   the certificate value;
2.   minus the certificate administrative charge, prorated based on
     the number of days from the last certificate anniversary to
     the date of full surrender;
3.   minus any surrender charge.

Surrender Charge
If the owner surrenders all or part of the certificate, there may
be a surrender charge.  A surrender charge applies if all or part
of the certificate value is surrendered during the first six
payment years following a purchase payment.  The surrender charge
schedule is:

     Payment Year    Surrender Charge
          1          6% of purchase payment surrendered
          2          5% of purchase payment surrendered
          3          4% of purchase payment surrendered
          4          3% of purchase payment surrendered
          5          2% of purchase payment surrendered
          6          1% of purchase payment surrendered
     Thereafter      0% of purchase payment surrendered

After the first certificate year each year the owner may surrender
up to 10 percent of the certificate value on the prior certificate
anniversary without incurring a surrender charge.  There is also no
surrender charge after the first certificate year on certificate
earnings defined as:

1.   the certificate value at the time of surrender; minus
2.   the sum of all purchase payments received that have not been
     previously surrendered; minus
3.   the amount of the 10% free withdrawal, if applicable.

For purposes of determining the surrender charge, surrenders will
be deemed to be taken:

1.   First, from any applicable 10% free withdrawal amount.
     There is no surrender charge on any applicable 10% free
     withdrawal amount.

2.   Next, from certificate earnings in excess of any applicable
     10% free withdrawal amount.
     There is no surrender charge on certificate earnings of any
     applicable 10% free withdrawal amount.

3.   Finally, from purchase payments on a first in -- first out
     basis.
     There is a surrender charge on purchase payments depending on
     the payment year of the purchase payment.

Surrender Charge Calculation
The surrender charge is calculated by multiplying the amount(s)
representing purchase payments by the applicable payment year
surrender charge percentage.

For example, the surrender charge on a total surrender request for
a certificate with this hypothetical history:
<PAGE>
PAGE 17
1.   a $10,000 purchase payment in payment year 5; and
2.   a $20,000 purchase payment in payment year 2; and
3.   a $40,000 prior anniversary value at time of surrender; and
4.   a $42,000 certificate value when surrendered in certificate
     year 5; and
5.   no previous surrenders

is calculated this way:
<TABLE><CAPTION>
Surrender Charge          Explanation
       <S>                        <C>
     $   0                $4,000 (10% of $40,000 prior anniversary
                          value free withdrawal amount) without
                          surrender charge
     $   0                $8,000 (certificate earnings in excess of
                          applicable 10% free withdrawal amount)
                          without surrender charge
     $ 200                $10,000 times 2% (payment year 5 surrender
                          charge percentage)
     $1000                $20,000 times 5% (payment year 2 surrender
                          charge percentage)
     $1200
</TABLE>
Rules for Surrender
All surrenders will have the following conditions:

1.   The owner must apply by written request or other method agreed
     to by us:

     (a)  while the certificate is in force; and
     (b)  prior to the earlier of the retirement date or the death
          of the annuitant.

2.   The owner must surrender an amount equal to at least $500. 
     Each variable subaccount value and the fixed account value
     after a partial surrender must be either $0 or at least $500.

3.   The amount surrendered, less any charges, will normally be
     paid to the owner within seven days of the receipt of the
     written request and the certificate, if required.  For
     surrenders from the fixed account, we have the right to defer
     payment for up to 6 months from the date we receive the
     surrender request.

4.   For partial surrenders, if the owner does not specify from
     which account the surrender is to be made, the surrender will
     be made from the variable subaccounts and the fixed account in
     the same proportion as the owner's interest in each bears to
     the certificate value.

Upon surrender for the full surrender value the certificate will
terminate.  We may require that the owner return the certificate to
us before we pay the full surrender value.

TSA Distribution Restrictions
To meet the requirements of Section 403(b) of the Code, unless
otherwise provided in the Code, no amounts may be distributed from
TSA contracts or certificates unless the owner has:
<PAGE>
PAGE 18
1.   attained age 59 1/2; or
2.   separated from service; or
3.   died; or
4.   become disabled (as defined in Section 72(m)(7) of the Code);
     quoted below:

     'MEANING OF DISABLED - For purposes of this section, an
     individual shall be considered to be disabled if he is unable
     to engage in any substantial gainful activity by reason of any
     medically determinable physical or mental impairment which can
     be expected to result in death or to be of long-continued and 
     indefinite duration.  An individual shall not be considered to
     be disabled unless he furnishes proof of the existence thereof
     in such form and manner as the Secretary may require.'; or

5.   encountered hardship (within the meaning of Section 403(b) of
     the Code);

and then only such amounts as the Code may provide.

We will require satisfactory written proof of the event(s) in items
1 through 5 above prior to any distribution from a certificate.

Suspension or Delay in Payment of Surrender
We have the right to suspend or delay the date of any surrender
payment from the variable subaccounts for any period:

1.   When the New York Stock Exchange is closed; or
2.   When trading on the New York Stock Exchange is restricted; or
3.   When an emergency exists as a result of which:
     (a)  disposal of securities held in the variable subaccounts
          is not reasonably practical; or
     (b)  it is not reasonably practical to fairly determine the
          value of the net assets of the variable subaccounts; or
4.   During any other period when the Securities and Exchange
     Commission, by order, so permits for the protection of
     security holders.

Rules and regulations of the Securities and Exchange Commission
will govern as to whether the conditions set forth in 2 and 3
exist.

Premature Distribution Penalty Tax
The owner may incur a federal 10% premature distribution penalty
tax.  This may occur if the owner surrenders all or a portion of
the certificate or settles the certificate using an annuity payment
plan prior to the close of the tax year in which the owner attains
age 59 1/2.

What minimum distributions does the Code require from tax-qualified
plans to plan participants?
Once a plan participant reaches age 70 1/2, the Code requires the
participant receive certain minimum distributions from the tax-
qualified plan each year.  IRAs, SEP/IRAs, TSAs and Code Section
401 retirement plans are subject to this minimum distribution
requirement.  Generally, distributions must begin no later than
April 1 following the year in which the participant reaches age 70
1/2.  Minimum distribution requirements may be satisfied by making<PAGE>
PAGE 19
partial surrenders from time to time or by settlement of a
certificate using an annuity payment plan.  Certificate owners
should consult their tax advisers to determine required minimum
distributions and the method of satisfying the minimum distribution
requirements which best meets the owners' objectives.

MINIMUM CERTIFICATE ACCUMULATION VALUES AND CASH SURRENDER VALUES
PRIOR TO SETTLEMENT PER $1,000 OF INITIAL PAYMENT*
<TABLE><CAPTION>
                          Symphony             Symphony
End of                    Minimum              Minimum
Certificate               Accumulation         Surrender
Year                      Values               Values
<S>                               <C>                       <C>
1                         $1,037.00            $  977.00
2                          1,075.48             1,027.08
3                          1,115.50             1,075.50
4                          1,157.12             1,127.12
5                          1,200.40             1,180.40

6                          1,245.42             1,235.42
7                          1,292.24             1,292.24
8                          1,340.93             1,340.93
9                          1,391.56             1,391.56
10                         1,444.23             1,444.23

11                         1,499.00             1,499.00
12                         1,555.96             1,555.96
13                         1,615.19             1,615.19
14                         1,676.80             1,676.80
15                         1,740.87             1,740.87

16                         1,807.51             1,807.51
17                         1,876.81             1,876.81
18                         1,948.88             1,948.88
19                         2,023.84             2,023.84
20                         2,101.79             2,101.79
</TABLE>
*Based on the minimum interest rate of 4% per year, compounded
annually.  Assumptions:

1.   There is a $10,000 initial purchase payment received and
     allocated 100% to the fixed account; and
2.   There are no additional payments; and
3.   There are no premium tax charges; and
4.   There are no surrenders.

If purchase payments are otherwise paid or allocated, or if there
are surrenders, or premium tax charges, the values above will be
changed in accordance with the provisions of the Group Contract.

ANNUITY PROVISIONS

Settlement
When certificate settlement occurs, the certificate value will be
applied to make fixed dollar annuity payments.  The first payment
will be made as of the retirement date.  This date is shown under
Certificate Data, in the certificate.  Before payments begin we
will require satisfactory proof that the annuitant is alive.  We<PAGE>
PAGE 20
may also require that the owner exchange the certificate for a
supplemental contract or certificate which provides the annuity
payments.

Change of Retirement Date
The owner may change the retirement date shown in Certificate Data
for the certificate.  The owner must tell us the new date by
written request.  If the owner selects a new date, it must be at
least 30 days after we receive the written request at our home
office.

The retirement date on tax-qualified certificates cannot be later
than the later of:

1.   the April 1 following the calendar year in which the annuitant
     attains age 70 1/2; or
2.   such other date which allows satisfaction of the minimum
     distribution requirements under the Code, its regulations
     and/or promulgations by the Internal Revenue Service; or
3.   such other date which allows satisfaction of the tax qualified
     plan's requirements.

Notwithstanding the above, and for all non-qualified certificates,
the retirement date may not be later than the later of:

1.   the annuitant's 85th birthday; or
2.   the tenth certificate anniversary.

Annuity Payment Plans
Annuity payments are made on a fixed dollar basis.  The owner may
schedule receipt of annuity payments according to one of the Plans
A through E below or another plan agreed to by us.

If this is an IRA or tax-qualified certificate, any such plan will
be calculated in accordance with the Code and must be provided:

(a)  in equal or substantially equal payments over a period no
     longer than the life of the annuitant or over the life of the
     annuitant and a joint annuitant; or
(b)  in equal or substantially equal payments over a period which
     does not exceed the life expectancy of the annuitant and a
     joint annuitant; or
(c)  any plan selected must also meet the incidental death benefit
     requirements, if any, under the Code.

Plan A - This provides monthly annuity payments during the lifetime
of the annuitant.  No payments will be made after the annuitant
dies.                

Plan B - This provides monthly annuity payments during the lifetime
of the annuitant with a guarantee by us that payments will be made
for a period of at least five, ten or fifteen years.  The owner
must select the guaranteed period.

Plan C - This provides monthly annuity payments during the lifetime
of the annuitant with a guarantee by us that payments will be made
for a certain number of months.  We determine the number of months<PAGE>
PAGE 21
by dividing the amount applied under this plan by the amount of the
first monthly annuity payment.

Plan D - Monthly payments will be paid during the lifetime of the
annuitant and joint annuitant.  When either the annuitant or the
joint annuitant dies we will continue to make monthly payments
during the lifetime of the survivor.  No payments will be made
after the death of both the annuitant and joint annuitant.

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

Plan Selection Requirements
The owner may select the plan by written request to us at least 30
days before the retirement date.

If at least 30 days before the retirement date we have not received
at our home office the owner's written request to select a plan, we
will make fixed dollar payments according to Plan B with payments
guaranteed for ten years.

If the owner selects a plan that has a payment amount that is the
same as another plan having a longer guarantee period, then the
plan with the longer guarantee period will be deemed to have been
chosen.

If the amount to be applied to a plan would not provide a monthly
payment of at least $50, we have the right to change the frequency
of the payment or to make a lump sum payment of the certificate
value.

Fixed Annuity
A fixed annuity is an annuity with payments that are guaranteed by
us as to dollar amount.  Fixed annuity payments after the first
will never be less than the amount of the first payment.  At
settlement the fixed account certificate value will be applied to
our fixed dollar Table of Settlement Rates then in effect.

This will be done in accordance with the payment plan chosen.  The
minimum amount payable for each $1,000 so applied is shown in sex
distinct Table A (non-qualified and IRA certificates) and unisex
Table B (tax-qualified and SEP-IRA certificates) on pages 23 and
24.

TABLE OF SETTLEMENT RATES

The amount of the first and all subsequent monthly fixed dollar
annuity payments for each $1,000 of value applied under any payment
plan will be based on our fixed dollar Table of Settlement Rates in
effect on the settlement date.  Such rates are guaranteed to be not
less than those shown in sex distinct Table A (non-qualified and
IRA certificates) on page 23 and unisex Table B (tax-qualified
certificates including SEP/IRA certificates but excluding IRA
certificates) on page 24.

In addition, the amount of such fixed annuity payment will not be
less than that which would be provided if a single premium<PAGE>
PAGE 22
immediate annuity contract then offred by us to annuitants in the
same class were to be purchased with the greater of:

1.   the cash surrender value of the certificate; or
2.   95% of the accumulation value of the certificate.

For non-qualified and IRA certificates, the amount of such fixed
annuity payments under Plans A, B and C will depend upon the sex
and the adjusted age of the annuitant on the date of settlement.  
The amount of such annuity payments under Plan D will depend on the
sex and adjusted age of the annuitant and the joint annuitant on
the date of settlement.

For tax-qualified and SEP-IRA certificates, the amount of such
fixed annuity payments under Plans A, B and C will depend upon the
adjusted age of the annuitant on the date of settlement.  The
amount of such annuity payments under Plan D will depend on the
adjusted age of the annuitant and the joint annuitant on the date
of settlement.

Adjusted age shall be equal to the age on the nearest birthday
minus an "adjustment" depending on the calendar year of birth of
the annuitant as follows:
                                                      
     Calendar Year of Annuitant's Birth  Adjustment
     Prior to 1920                             0
     1920 through 1924                         1
     1925 through 1929                         2
     1930 through 1934                         3
     1935 through 1939                         4
     1940 through 1944                         5
     1945 through 1949                         6
     1950 through 1959                         7
     1960 through 1969                         8
     1970 through 1979                         9
     1980 through 1989                         10
     After 1989                                11<PAGE>
PAGE 23
<TABLE><CAPTION>
TABLE A - TABLE OF FIXED DOLLAR SETTLEMENT RATES
NON-QUALIFIED AND IRA CERTIFICATES

Amount of Each Monthly Fixed Dollar Annuity Payment Per $1,000 Applied
                                                                                             
     Life      5 Years         10 Years        15 Years       With
Adj. Income    Certain         Certain         Certain        Refund
Age* M    F    M     F    M    F    M    F     M    F
<S>    <C>    <C>   <C>    <C>    <C>   <C>    <C>    <C>   <C>    <C><C>
45   4.53 4.24 4.52  4.23 4.50 4.23 4.46 4.21  4.42 4.19
46   4.59 4.28 4.58  4.28 4.55 4.27 4.51 4.25  4.47 4.23
47   4.65 4.33 4.64  4.33 4.61 4.32 4.56 4.30  4.52 4.27
48   4.72 4.38 4.71  4.38 4.67 4.37 4.62 4.34  4.58 4.32
49   4.79 4.44 4.77  4.43 4.74 4.42 4.68 4.39  4.63 4.36

50   4.86 4.50 4.85  4.49 4.81 4.47 4.74 4.45  4.69 4.41
51   4.94 4.56 4.92  4.55 4.88 4.53 4.80 4.50  4.76 4.47
52   5.02 4.62 5.00  4.61 4.95 4.59 4.87 4.56  4.82 4.52
53   5.10 4.69 5.08  4.68 5.03 4.66 4.94 4.62  4.90 4.58
54   5.19 4.76 5.17  4.75 5.11 4.72 5.01 4.68  4.97 4.64

55   5.29 4.84 5.26  4.83 5.20 4.80 5.09 4.74  5.05 4.71
56   5.39 4.92 5.36  4.91 5.29 4.87 5.17 4.81  5.13 4.77
57   5.49 5.00 5.47  4.99 5.38 4.95 5.25 4.88  5.21 4.85
58   5.61 5.09 5.58  5.08 5.48 5.03 5.33 4.96  5.30 4.92
59   5.73 5.19 5.70  5.17 5.59 5.12 5.42 5.04  5.40 5.00

60   5.86 5.29 5.82  5.27 5.70 5.22 5.51 5.12  5.50 5.09
61   6.00 5.40 5.96  5.38 5.82 5.32 5.60 5.21  5.60 5.18
62   6.16 5.52 6.10  5.50 5.95 5.42 5.69 5.30  5.72 5.27
63   6.32 5.65 6.26  5.62 6.08 5.53 5.79 5.39  5.83 5.37
64   6.49 5.78 6.42  5.75 6.21 5.65 5.89 5.49  5.96 5.48

65   6.68 5.92 6.60  5.89 6.35 5.77 5.98 5.58  6.09 5.59
66   6.88 6.08 6.78  6.03 6.50 5.90 6.08 5.69  6.23 5.71
67   7.09 6.24 6.98  6.19 6.65 6.04 6.18 5.79  6.38 5.83
68   7.31 6.42 7.18  6.36 6.81 6.19 6.28 5.90  6.53 5.97
69   7.56 6.61 7.40  6.54 6.97 6.34 6.37 6.01  6.69 6.11

70   7.82 6.81 7.64  6.74 7.14 6.50 6.47 6.12  6.86 6.26
71   8.09 7.04 7.88  6.95 7.31 6.67 6.55 6.22  7.04 6.42
72   8.39 7.28 8.14  7.17 7.48 6.84 6.64 6.33  7.23 6.59
73   8.71 7.54 8.41  7.41 7.65 7.02 6.72 6.44  7.43 6.77
74   9.05 7.83 8.70  7.67 7.83 7.21 6.80 6.54  7.64 6.97

75   9.41 8.14 9.00  7.95 8.00 7.40 6.87 6.64  7.86 7.17
                                                                                             
/TABLE
<PAGE>
PAGE 24
<TABLE><CAPTION>
[Table A, cont'd]
Plan D - Joint and Survivor

Adj. Adjusted Age of Female Joint Annuitant
Male 10 Years  5 Years    Same      5 Years    10 Years
Age* Younger   Younger    Age       Older      Older
<S>    <C>          <C>           <C>          <C>          <C>
45   3.80      3.89       3.99      4.10       4.19
46   3.82      3.92       4.03      4.14       4.24
47   3.85      3.95       4.07      4.18       4.29
48   3.87      3.98       4.10      4.22       4.34
49   3.90      4.02       4.15      4.27       4.39

50   3.93      4.06       4.19      4.32       4.45
51   3.96      4.09       4.23      4.38       4.51
52   4.00      4.13       4.28      4.43       4.57
53   4.03      4.18       4.33      4.49       4.64
54   4.07      4.22       4.39      4.56       4.72

55   4.11      4.27       4.45      4.62       4.79
56   4.15      4.32       4.51      4.70       4.88
57   4.19      4.37       4.57      4.77       4.96
58   4.24      4.43       4.64      4.85       5.06
59   4.28      4.49       4.71      4.94       5.16

60   4.34      4.55       4.79      5.03       5.27
61   4.39      4.62       4.87      5.13       5.38
62   4.45      4.69       4.96      5.24       5.50
63   4.51      4.77       5.06      5.35       5.64
64   4.57      4.85       5.16      5.48       5.78

65   4.64      4.94       5.27      5.61       5.93
66   4.71      5.03       5.38      5.75       6.09
67   4.79      5.13       5.51      5.90       6.27
68   4.87      5.24       5.64      6.06       6.46
69   4.96      5.35       5.78      6.24       6.66

70   5.06      5.47       5.94      6.43       6.87
71   5.16      5.60       6.10      6.63       7.11
72   5.26      5.74       6.28      6.84       7.36
73   5.38      5.89       6.47      7.08       7.62
74   5.50      6.05       6.68      7.33       7.91

75   5.63      6.22       6.90      7.60       8.22
                                                                                             
*Adjusted Age of annuitant.  Refer to the explanation of adjusted age on page 22.
M = Male  F = Female
                                                                                             
The table above is based on the "1983 Individual Annuitant Mortality Table A" assuming an
interest rate of 4% per year compounded annually.  Settlement rates for any age, or any
combination of age and sex not shown above, will be calculated on the same basis as those
rates shown in the table above.  Such rates will be furnished by us upon request.  Amounts
shown in the table below are based on an assumed interest rate of 4% per year compounded
annually.
                                                                                             
</TABLE>
<TABLE><CAPTION>
Plan E - Dollar Amount of Each Monthly Fixed Dollar Annuity Payment Per $1,000 Applied
                                                                         
     Years      Monthly         Years     Monthly         Years     Monthly
     Payable    Payment         Payable   Payment         Payable   Payment
       <S>          <C>                 <C>           <C>                 <C>          <C>
     10         $10.06          17        $6.71           24        $5.35
     11           9.31          18         6.44           25         5.22
     12           8.69          19         6.21           26         5.10
     13           8.17          20         6.00           27         5.00
     14           7.72          21         5.81           28         4.90
     15           7.34          22         5.64           29         4.80
     16           7.00          23         5.49           30         4.72
                                                                                             
/TABLE
<PAGE>
PAGE 25
<TABLE><CAPTION>
TABLE B - TABLE OF FIXED DOLLAR SETTLEMENT RATES
TAX-QUALIFIED CERTIFICATES (Includes SEP/IRA Certificates, Excludes IRA Certificates)          
Amount of Each Monthly Fixed Dollar Annuity Payment Per $1,000 Applied
                                                                                              
           Plan A         Plan B          Plan C
                                                                                              
Adj. Life       5 Years   10 Years        15 Years        With
Age* Income     Certain   Certain         Certain         Refund
<S>    <C>          <C>           <C>                 <C>                 <C>
45   4.24       4.23      4.21            4.21            4.19
46   4.28       4.28      4.27            4.25            4.23
47   4.33       4.33      4.32            4.30            4.27
48   4.38       4.38      4.37            4.34            4.32
49   4.44       4.43      4.42            4.39            4.36

50   4.50       4.49      4.47            4.45            4.41
51   4.56       4.55      4.53            4.50            4.47
52   4.62       4.61      4.59            4.56            4.52
53   4.69       4.68      4.66            4.62            4.58
54   4.76       4.75      4.72            4.68            4.64

55   4.84       4.83      4.80            4.74            4.71
56   4.92       4.91      4.87            4.71            4.77
57   5.00       4.99      4.95            4.88            4.85
58   5.09       5.08      5.03            4.96            4.92
59   5.19       5.17      5.12            5.04            5.00

60   5.29       5.27      5.22            5.12            5.09
61   5.40       5.38      5.32            5.21            5.18
62   5.52       5.50      5.42            5.30            5.27
63   5.65       5.62      5.53            5.39            5.37
64   5.78       5.75      5.65            5.49            5.48

65   5.92       5.89      5.77            5.58            5.59
66   6.08       6.03      5.90            5.69            5.71
67   6.24       6.19      6.04            5.79            5.83
68   6.42       6.36      6.19            5.90            5.97
69   6.61       6.54      6.34            6.01            6.11

70   6.81       6.74      6.50            6.12            6.26
71   7.04       6.95      6.67            6.22            6.42
72   7.28       7.17      6.84            6.33            6.59
73   7.54       7.41      7.02            6.44            6.77
74   7.83       7.67      7.21            6.54            6.97

75   8.14       7.95      7.40            6.64            7.17
                                                                                              
</TABLE>
<TABLE><CAPTION>
[Table B, cont'd]
Plan D - Joint and Survivor

     Adjusted Age of Joint Annuitant
Adj. 10 Years   5 Years   Same            5 Years         10 Years
Age* Younger    Younger   Age             Older           Older
<S>    <C>          <C>           <C>                 <C>                 <C>          
45   3.77       3.85      3.93            4.00            4.07
46   3.79       3.88      3.96            4.04            4.10
47   3.82       3.91      3.99            4.08            4.15
48   3.84       3.94      4.03            4.12            4.19
49   3.87       3.97      4.07            4.16            4.24

50   3.90       4.00      4.11            4.20            4.28
51   3.93       4.04      4.15            4.25            4.34
52   3.96       4.08      4.19            4.30            4.39
53   3.99       4.12      4.24            4.35            4.45
54   4.03       4.16      4.29            4.41            4.51

55   4.07       4.20      4.34            4.47            4.58
56   4.10       4.25      4.40            4.53            4.65
57   4.15       4.30      4.45            4.60            4.72
58   4.19       4.35      4.52            4.67            4.80
59   4.24       4.41      4.58            4.75            4.89

60   4.28       4.47      4.65            4.83            4.98
61   4.34       4.53      4.73            4.92            5.07
62   4.39       4.60      4.81            5.01            5.18<PAGE>
PAGE 26 
63   4.45       4.67      4.90            5.11            5.29
64   4.51       4.75      4.99            5.21            5.41

65   4.58       4.83      5.09            5.33            5.53
66   4.65       4.92      5.19            5.45            5.67
67   4.72       5.01      5.30            5.58            5.81
68   4.80       5.11      5.42            5.72            5.97
69   4.89       5.21      5.55            5.88            6.14

70   4.98       5.33      5.69            6.04            6.33
71   5.07       5.45      5.85            6.22            6.52
72   5.18       5.58      6.01            6.41            6.74
73   5.29       5.72      6.19            6.62            6.97
74   5.41       5.88      6.38            6.84            7.22

75   5.53       5.53      6.58            7.09            7.49
                                                                                              
*Adjusted Age of annuitant.  Refer to the explanation of adjusted age on page 22.
                                                                                         
The table above is based on the "1983 Individual Female Annuitant Mortality Table A" assuming an interest rate of 4% per year
compounded annually.  Settlement rates for any age not shown above will be calculated on the same basis as those rates shown in the
table above.  Such rates will be furnished by us upon request.  Amounts shown in the table below are based on an assumed interest
rate of 4% per year compounded annually.
                                                                                             
</TABLE>
<TABLE><CAPTION>
Plan E - Dollar Amount of Each Monthly Fixed Dollar Annuity Payment Per $1,000 Applied
                                                                         
     Years      Monthly         Years     Monthly         Years     Monthly
     Payable    Payment         Payable   Payment         Payable   Payment
       <S>          <C>                 <C>           <C>                 <C>          <C>
     10         $10.06          17        $6.71           24        $5.35
     11           9.31          18         6.44           25         5.22
     12           8.69          19         6.21           26         5.10
     13           8.17          20         6.00           27         5.00
     14           7.72          21         5.81           28         4.90
     15           7.34          22         5.64           29         4.80
     16           7.00          23         5.49           30         4.72
                                                                                            
</TABLE>
<PAGE>
PAGE 1
GROUP DEFERRED ANNUITY CERTIFICATE

This annuity certificate summarizes the provisions of the Group
Deferred Annuity Contract specified on the enrollment application. 
It does not amend or modify any of the provisions of the Group
Contract.  All rights, privileges and benefits are governed by the
provisions of the Group Contract.  The Group Contract may be
inspected by the certificate owner or annuitant at the
Contractholder's office during office hours.

If the annuitant is living on the Retirement Date, we will begin to
pay you monthly annuity payments.  Any payments made by us are
subject to the Terms of the Group Contract.  Any payments made by
us are subject to the Terms of the Group Contract. [sic]

We issue this ccertificate in consideration of your enrollment
application and the payment of the single purchase payment.

Signed for and issued by IDS Life Insurance Company of New York,
Albany, New York, as of the certificate date shown below.

ACCUMULATION VALUES, WHEN BASED ON THE INVESTMENT RESULTS OF THE
SEPARATE ACCOUNT, ARE VARIABLE AND NOT GUARANTEED AS TO FIXED
DOLLAR AMOUNT.

Group Deferred Annuity Certificate

- - Flexible purchase payments
- - Optional fixed dollar or variable accumulation values
- - Fixed dollar annuity payments
- - Annuity payments to begin on the retirement date
- - This certificate is nonparticipating.  Dividends are not payable.

VARIABLE PROVISIONS ARE FOUND ON PAGE 9

NOTICE OF YOUR RIGHT TO EXAMINE THIS CERTIFICATE FOR 20 DAYS
If for any reason you are not satisfied with this certificate,
return it to us or our agent within 20 days after you receive it. 
We will then cancel this certificate.  We will refund all payments
made.  This certificate will then be considered void from its
start.

President
\s\ James A. Mitchell

Secretary
\s\Michael B. Carlin<PAGE>
PAGE 2
GUIDE TO CERTIFICATE PROVISIONS

Definitions
Important words and meanings/Page 3

General Provisions
Entire contract; Contract modification; Incontestability; Benefits
based on incorrect data; State laws, Reports to owner; Evidence of
survival; Protection of proceeds; Payments by us; Voting
rights/Page 4

Ownership and Beneficiary
Owner rights; Change of ownership; Beneficiary; Change of
Beneficiary; Assignment/Page 5

Payments to Beneficiary
Describes options and amounts payable upon death/Page 6

Purchase Payments
Purchase payments amounts; Payment limits; Allocations of purchase
payments/Page 7

Certificate Value
Describes the fixed and variable account certificate values;
Interest to be credited; Certificate administrative charge; Premium
taxes; Transfers of Contract Values/Page 8

Fixed and Variable Accounts
Describes the fixed account; Describes the variable subaccounts,
accumulation units and values; Net investment factor; Mortality and
expense risk charge; Variable account administrative charge/Page 9

Surrender Provisions
Surrender of the certificate for its surrender value; Rules for
surrender; Premature distribution penalty tax/Page 11

Annuity Provisions
When annuity payments begin; Different ways to receive annuity
payments; Determination of payment amounts/Page 13

Table of Settlement Rates
Table showing the amount of the fixed dollar annuity payments for
the various payment plans/Page 14<PAGE>
PAGE 3
THE CERTIFICATE PROVISIONS WILL CONTROL IN THE EVENT OF A CONFLICT
BETWEEN CERTIFICATE PROVISIONS AND CONTRACT PROVISIONS

CERTIFICATE DATA

Upon issuance of this certificate your initial purchase payment has
been applied to the fixed and variable accounts as shown below. 
You may make additional payments and change the purchase payment
allocation as provided in the Group Contract.  Refer to the
purchase payments provision on Page 7.

                               Purchase Payment
     Variable Subaccounts      Allocation Percentage
     Money Market                   10%
     Intermediate High Grade        10%
     Diversified Strategic Income   10%
     Equity Income                  10%
     Equity Index                   10%
     Growth & Income                10%
     Appreciation                   10%
     Fixed Account                  30%

Surrender Charge:  If you surrender all or a portion of this
certificate surrender charges may apply.  A surrender charge
applies if all or part of the certificate value is surrendered
during the first six payment years following a purchase payment. 
The surrender charge schedule is:

   Payment Year      Surrender Charge
     1         6% of purchase payment surrendered
     2         5% of purchase payment surrendered
     3         4% of purchase payment surrendered
     4         3% of purchase payment surrendered
     5         2% of purchase payment surrendered
     6         1% of purchase payment surrendered
   Thereafter  0% of purchase payment surrendered

After the first certificate year, you may surrender up to 10
percent of your prior certificate anniversary certificate value
each certificate year without incurring a surrender charge.  There
is also no surrender charge after the first certificate anniversary
on certificate earnings defined as:

1.   the certificate value; minus
2.   the sum of all purchase payments received that have not been
     previously surrendered; minus
3.   the amount of the 10% free withdrawal, if applicable.

Refer to the surrender charge provision on Page 10 for additional
surrender charge information.

Certificate Administrative Charge:  See Page 8.

Maximum Total Purchase Payments in the first and later certificate
years are $1,000,000.  We reserve the right to change this maximum
on a uniform basis for all certificateholders in a class.
<PAGE>
PAGE 4
CERTIFICATE DATA

Annuitant:                John Doe
Certificate Number:       990-SAMPLE
Single Purchase Payment:  $10,000.00
Certificate Type:         Non-qualified

Certificate Owner:        John Doe
Certificate Date:         November 1, 1991
Retirement Date:          November 1, 2021

Annuitant:     John Doe   Certificate Number:    990-SAMPLE

Fixed Account
Table of Guaranteed Minimum Certificate and Surrender Values
Guaranteed Interest Rate:  4% Per Year Compounded Annually

The following table shows the guaranteed minimum fixed account
certificate and surrender values based on these assumptions:

(1)  $10,000 initial purchase payment received and allocated 100%
     to the fixed account;
(2)  There are no additional payments;
(3)  There are no premium tax charges.
(4)  There are no surrenders.

If purchase payments are otherwise paid or allocated or if there
are surrenders, or premium tax charges, the values below will be
adjusted in accordance with the provisions of the Group Contract.

End of    Guaranteed           Guaranteed
Certificate    Minimum         Minimum
/Payment  Certificate          Fixed Account
Year      Certificate Value    Surrender Value
1         $10,370.00           $9,770.00
2          10,754.80           10,270.83
3          11,154.99           10,754.99
4          11,571.19           11,271.19
5          12,004.04           11,804.04

6          12,454.20           12,354.20
7          12,922.37           12,922.37
8          13,409.26           13,409.26
9          13,915.63           13,915.63
10         14,442.26           14,442.26

11         14,989.95           14,989.95
12         15,559.55           15,559.55
13         16,151.93           16,151.93
14         16,768.01           16,768.01
15         17,408.73           17,408.73

16         18,075.08           18,075.08
17         18,768,08           18,768.08
18         19,488.80           19,488.80
19         20,238.35           20,238.35
20         21,017.89           21,017.89
<PAGE>
PAGE 5
21         21,828.60           21,828.60
22         22,671.75           22,671.75
23         23,548.62           23,548.62
24         24,460.56           24,460.56
25         25,408.99           25,408.99

26         26,395.35           26,395.35
27         27,421.16           27,421.16
28         28,488.01           28,488.01
29         29,597.53           29.597.53
30         30,751.43           30,751.43

Variable account certificate and surrender values are not
guaranteed.  Information concerning certificate and surrender
values will be provided to you at any time upon written request.

DEFINITIONS

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

annuitant
The person on whose life monthly annuity payments depend.

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

we, us, our
IDS Life Insurance Company of New York

accumulation unit
An accumulation unit is an accounting unit.  It is used to
calculate the certificate value prior to settlement.

certificate date
It is the date from which certificate anniversaries, certificate
years, and certificate months are determined.  Your certificate
date is shown under Certificate Data.

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

payment year
Each certificate year in which you make a purchase payment and each
succeeding year measured from the end of the certificate year
during which you made such a purchase payment.  For example, if you
make an initial purchase payment of $15,000 and then make an
additional purchase payment of $10,000 during the 4th certificate
year, the 6th certificate year will be:

     -    the 6th payment year with respect to your initial $15,000
          purchase payment; and
     -    the 3rd payment year with respect to your additional
          $10,000 purchase payment
<PAGE>
PAGE 6
certificate value
The sum of the: (1) Fixed Account Certificate Value; and the (2)
Variable Account Certificate Value.

retirement date
The date shown under Certificate Data on which annuity payments are
to begin.  This date may be changed as provided in this
certificate.

settlement
The application of the certificate value of this certificate to
provide fixed dollar annuity payments.

valuation date
A valuation date is each day the New York Stock Exchange is open
for trading.

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

fixed account
The fixed account is made up of all our assets other than those in
any separate account.

variable account
The variable account is a separate investment account of ours.  It
consists of several subaccounts.  Each subaccount is named under
Certificate Data, in the certificate.

fixed annuity
A fixed annuity is an annuity with payments which are guaranteed by
us as to dollar amount during the annuity payment period.

written request
A request in writing signed by you and delivered to us at our home
office.

Code
The Internal Revenue Code of 1986, as amended, and all related laws
and regulations which are in effect during the term of this
certificate.

GENERAL PROVISIONS

Entire Contract
The entire contract consists of: the Group Contract; the
application of the Group Contractholder, which is attached to the
Group Contract; and the enrollment application.

No one except one of our corporate officers (President, Vice
President, Secretary or Assistant Secretary) can change or waive
any of our rights or requirements under the contract.  That person
must do so in writing.  None of our representatives or other
persons has the authority to change or waive any of our rights or
requirements under the contract.
<PAGE>
PAGE 7
Contract Modification
We will modify the Group Contract and certificates if needed to
qualify certificates issued under the contract as annuity
certificates under Section 72 of the Code and all related laws and
regulations which are in effect during the term of the contract. 

We will obtain the approval of the State of New York and any other
regulatory authority for the modifications.  We will provide you
with notice and copy of any such modifications, approved for use in
the state of jurisdiction, and an explanation of their effect upon
your certificate.  You may reject the modifications by writing to
us.

Incontestable
This certificate is incontestable from its date of issue.

Benefits Based on Incorrect Data
If the amount of benefits is determined by data as to a person's
age or sex that is incorrect, benefits will be recalculated on the
basis of the correct data.

Any underpayments made by us will immediately be paid in a single
sum with an interest credit of 6% per annum.

Any overpayments made by us will be subtracted from the future
payments together with an interest credit of 6% per annum.

State Laws
This certificate is governed by the law of the state in which it is
delivered to the certificate owner.  The values and benefits of
this certificate are at least equal to those required by such state
and by the state in which the Group Contract is delivered to the
Group Contractholder.  Any paid up annuity, cash surrender or death
benefit is not less than the minimum benefit required by any
statute of such state.

Reports to Owner
At least once a year we will send you a statement showing the
certificate value and the certificate cash surrender value.  The
statement will be based on the laws and regulations of the state in
which the certificate is delivered to the certificate owner and of
any other applicable laws or regulations that apply to the Group
Contract.

Evidence of Survival
Where any payments under this certificate depend upon the recipient
or annuitant being alive on a certain date, proof that such
condition has been met may be required by us.  Such proof may be
required prior to making the payments.

Protection of Proceeds
Payments under this certificate are not assignable by any
beneficiary prior to the time they are due.  To the extent allowed
by law, payments are not subject to the claims of creditors or
legal process.
<PAGE>
PAGE 8
Payments by Us
All sums payable by us are payable at our home office.  Any payment
of a variable annuity or surrender based upon the variable
certificate value shall be payable only from the variable accounts.

Voting Rights
So long as federal law requires, you may have the right to vote at
the meetings of the Variable Shareholders.  If you have voting
rights we will send a notice to you telling the time and place of a
meeting.  The notice will also explain matters to be voted upon and
how many votes you get.

OWNERSHIP AND BENEFICIARY

Owner Rights
As long as the annuitant is living and unless otherwise provided in
this certificate, you may exercise all rights and privileges
provided in this certificate or allowed by us.  Your entire
interest is non-forfeitable.

Change of Ownership

You may change the ownership of this certificate.

Any change of ownership must be made by written request on a form
approved by us.  The change must be made while the annuitant is
living.  Once the change is received by us, it will take effect as
of the date of your request, subject to any action taken or payment
made by us before the receipt.

Beneficiary
Beneficiaries are those you have named in the enrollment
application or later changed as provided below, to receive benefits
of this certificate if you or the annuitant die while this
certificate is in force.

Only those beneficiaries who are living when death benefits become
payable may share in the benefits, if any.  If no beneficiary is
then living, we will pay the benefits to you, if living, otherwise
to your estate.

Change of Beneficiary
You may change the beneficiary anytime while the annuitant is
living by satisfactory written request to us.  Once the change is
received by us, it will take effect as of the date of your request,
subject to any action taken or payment made by us before the
receipt.

Assignment

You can assign this certificate or any interest in it while the
annuitant is living.  Your interest and the interest of any
beneficiary is subject to the interest of the assignee.  An
assignment is not a change of ownership and an assignee is not an
owner as these terms are used in this certificate.  Any amounts
payable to the assignee will be paid in a single sum.

A copy of any assignment must be submitted to us at our home
office.  Any assignment is subject to any action taken or payment<PAGE>
PAGE 9
made by us before the assignment was received at our home office. 
We are not responsible for the validity of any assignment.

PAYMENTS TO BENEFICIARY

Death Benefits Before the Retirement Date
If you or the annuitant die before the fifth certificate
anniversary while the certificate is in force, we will pay the
beneficiary the greater of the certificate value or the purchase
payments paid less any amounts surrendered.

On or after the initial fifth certificate anniversary, and each
subsequent fifth certificate anniversary thereafter, we will pay
the beneficiary the greater of the certificate value or a minimum
guaranteed death benefit which equals:

1.   the death benefit calculated as of the previous fifth
     certificate anniversary; plus
2.   any purchase payments made since the previous fifth
     certificate anniversary; minus
3.   any surrenders since the previous fifth certificate
     anniversary.

The above amount will be paid in a lump sum upon the receipt of due
proof of death of you or the annuitant, whichever first occurs. 
The beneficiary may elect to receive payment anytime within 5 years
after the date of death.

In lieu of a lump sum, payment may be made under an Annuity Payment
Plan, provided:

1.   The beneficiary elects the plan within 60 days after we
     receive proof of death; and
2.   The plan provides payments over a period which does not exceed
     the life or life expectancy of the beneficiary; and
3.   Payments must begin no later than one year after the date of
     death.

In this event, the reference to "annuitant" in the Annuity Payment
Plans section shall apply to the beneficiary.

Any amounts payable or applied by us as described in this section
will be based on the certificate value as of the valuation date on
or next following the date on which due proof of death is received
at our home office.

Required Distribution at Annuitant's Death Prior to the Retirement
Date
The Code requires a distribution on the death of the annuitant if a
certificate is owned by a corporation or other non-individual.  If
we receive due proof that the annuitant died while this certificate
was in force before settlement, we will pay to the beneficiary the
death benefit described in Death Benefits Before the Retirement
Date.  The death benefit will be determined as of the date on which
due proof of death is received at our home office.

Refer to the other provisions of this Payments to Beneficiary
section for an explanation of the distribution methods and<PAGE>
PAGE 10
distribution timing the beneficiary may elect.  A spouse
beneficiary, if eligible as explained in the provision below, may
elect spousal continuation.

Spouse's Option to Continue Certificate
If you die prior to the retirement date, and your spouse is the
sole beneficiary of the certificate, your spouse may forego receipt
of the death benefit and instead keep the certificate in force as
owner and may make additional purchase payments to the certificate. 
The election by your spouse must be made within 60 days after we
receive due proof of death.  Additional purchase payments may be
made to the annuity.

Death After the Retirement Date
If annuity payments are being made under Plans B, C or E (see
Annuity Provisions), any remaining guaranteed payments will be
continued to the beneficiary, if living; if not, your estate.

PURCHASE PAYMENTS

Purchase Payments
Purchase payments are the payments you make for this certificate
and the benefits it provides.  Purchase payments consist of your
initial purchase payment and any additional optional purchase
payments you make.  Purchase payments must be paid or mailed to us
at our home office or to an authorized agent.  If requested, we
will give you a receipt for your purchase payments.  Upon payment
to us, purchase payments become our property.

Net purchase payments are that part of your purchase payments
applied to the certificate value.  A net purchase payment is equal
to the purchase payment less any applicable premium tax charge.

Additional Purchase Payments
Additional purchase payments may be made until the earlier of:

1.   the date the certificate terminates by surrender or otherwise;
     or
2.   the date on which annuity payments begin.

Additional purchase payments are subject to the Payment Limits
Provision below.

Payment Limits Provision
Maximum Purchase Payments - The maximum total certificate purchase
payments may not exceed the amounts shown under Certificate Data. 
We reserve the right to increase the maximums on a uniform basis
for all certificateholders in a class.

Additional Purchase Payments - You may make additional purchase
payments of at least $500.

Allocation of Purchase Payments
You instruct us on how you want your purchase payments allocated
among the fixed account and the variable subaccounts.  Your choice
for the fixed account and each variable subaccount may be made in
any whole percent from 0% to 100%.  No allocation may be made that
would result in a fixed account or variable subaccount value of<PAGE>
PAGE 11
less than $500.  Your allocation instructions as of the certificate
date are shown under Certificate Data.

By written request, or by another method agreed to by us, you may
change the choice of accounts or percentages.  The first net
purchase payment will be allocated as of the date the purchase
payment is received at our home office.  Net purchase payments
after the first will be allocated as of the end of the valuation
period during which we receive the payment at our home office.

CERTIFICATE VALUE

Certificate Value
The certificate value of a certificate at any time is the sum of:

1.   the Fixed Account Certificate Value; and
2.   the Variable Account Certificate Value.

If:

1.   part or all of the certificate value is surrendered; or
2.   charges described herein are made against the certificate
     value;

then a number of accumulation units from the variable subaccounts
and an amount from the fixed account will be deducted to equal such
amount.  For surrenders, deductions will be made from the fixed
account or variable subaccounts that you specify.  Otherwise, the
number of units from the variable subaccounts and the amount from
the fixed account will be deducted in the same proportion that your
interest in each bears to the total certificate value.

Fixed Account Certificate Value
The fixed account certificate value at any time will be:

1.   the sum of all amounts credited to the fixed account under the
     certificate; less
2.   any amounts deducted for charges or surrenders.

Interest to be Credited
We will credit interest to the fixed account certificate value. 
Interest will begin to accrue on the date the purchase payments are
received in our home office.  Such interest will be credited at
rates that we determine from time to time.  However, we guarantee
that the rate will not be less than the Guaranteed Interest Rate
shown under Certificate Data.

Variable Account Certificate Value
The variable account certificate value at any time will be:

1.   the sum of the value of all variable subaccount accumulation
     units under this certificate resulting from purchase payments
     so allocated, or transfers among the variable and fixed
     accounts; less
2.   any units deducted for charges or surrenders.

Certificate Administrative Charge
We charge a fee for establishing and maintaining our records for
this certificate.  The charge is $30 per year and is deducted from<PAGE>
PAGE 12
the certificate value at the end of each certificate year.  The
charge deducted will be prorated among the variable subaccounts and
the fixed account in the same proportion your interest in each
bears to the total certificate value.

If you fully surrender this certificate, we deduct a certificate
administrative charge that is prorated based on the number of days
from your last certificate anniversary to the date of full
surrender.  The charge does not apply after settlement of this
certificate.

Premium Tax Charges
A charge will be made by us against the certificate value of this
certificate for any applicable premium taxes not previously
deducted.

Transfers of Certificate Values
While this certificate is in force prior to the settlement date,
transfers of certificate values may be made as outlined below:

1.   You may transfer all or a part of the values held in one or
     more of the variable subaccounts to another one or more of the
     variable subaccounts.

2.   You may transfer all or a part of the values held in one or
     more of the variable subaccounts to or from the fixed account
     subject to these restrictions:

     (a)  You may transfer certificate values from the fixed
          account to a variable subaccount, or vice versa, up to
          six times per certificate year subject to item (b) below.

     (b)  If a transfer is made from the fixed account to a
          variable subaccount, no transfer from any variable
          subaccount to the fixed account may be made for six
          months from the transfer date.

You may make a transfer by written request.  There is no fee or
charge for these transfers.  However, the minimum transfer amount
is $500, or if less, the entire value in the subaccount or in the
fixed account from which the transfer is being made, or such other
minimum amounts agreed to by us.

FIXED AND VARIABLE ACCOUNTS

The Fixed Account
The fixed account is our general account.  It is made up of all our
assets other than

1.   those in the variable account; and
2.   those in any other segregated asset account.

The Variable Account
The variable account is a separate investment account of ours.  If
consists of several subaccounts which are named under Certificate
Data.  We have allocated a part of our assets for this and certain
other certificates and contracts to the variable account.  Such
assets remain our property.  However, they may not be charged with
the liabilities from any other business in which we may take part.<PAGE>
PAGE 13
Investments of the Variable Account
Purchase payments applied to the variable account will be allocated
as specified by the owner.  Each variable subaccount will buy, at
net asset value, shares of the Portfolio shown for that subaccount
under Certificate Data or as later added or changed.

Valuation of Assets
Portfolio shares in the variable subaccounts will be valued at
their net asset value.

Variable Account Accumulation Units
The number of accumulation units for each of the variable
subaccounts is found by adding the number of accumulation units
resulting from:

1.   purchase payments allocated to the subaccount; and
2.   transfers to the subaccount;

and subtracting the number of certificate accumulation units
resulting from:

1.   transfers from the subaccount; and
2.   surrenders (including surrender charges) from the subaccount;
     and
3.   certificate administrative charge deductions from the
     subaccount.

The number of accumulation units added or subtracted for each of
the above transactions is found by dividing:

1.   the number allocated to or deducted from the subaccount; by
2.   the accumulation unit value for the subaccount for the
     respective valuation period during which we received the
     purchase payment or transfer value, or during which we
     deducted transfers, surrenders, surrender charges or
     certificate administrative charges.

Variable Account Accumulation Unit Value
The value of an accumulation unit for each of the variable
subaccounts was set at $1 when the first Portfolio shares were
bought.  The value for any later valuation period is found as
follows:

The accumulation unit value for each variable subaccount for the
last prior valuation period is multiplied by the net investment
factor for the same subaccount for the next following valuation
period.  The result is the accumulation unit value.  The value of
an accumulation unit may increase or decrease from one valuation
period to the next.

Net Investment Factor
The net investment factor is an index applied to measure the
investment performance of a variable subaccount from one valuation
period to the next.  The net investment factor may be greater or
less than one; therefore, the value of an accumulation unit may
increase or decrease.
<PAGE>
PAGE 14
The net investment factor for any such subaccount for any valuation
period is determined by: dividing (1) by (2) and subtracting (3)
and (4) from the result.  This is done where:

1.   is the sum of
     a.   the net asset value per share of the Portfolio held in
          the variable 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 variable
          subaccount, if the "ex-dividend" date occurs during the
          current valuation period.

2.   is the net asset value per share of the Portfolio held in the
     variable subaccount, determined at the end of the last prior
     valuation period.

3.   is a factor representing the mortality and expense risk
     charge.

4.   is a factor representing the variable account administrative
     charge.

Mortality and Expense Risk Charge
In calculating accumulation unit values we will deduct a mortality
and expense risk charge from the variable subaccounts equal, on an
annual basis, to 1.25% of the daily net asset value.  This
deduction is made to compensate us for assuming the mortality and
expense risks under certificates of this type.  The deduction will
be:

1.   made from each variable subaccount; and
2.   computed on a daily basis.

Variable Account Administrative Charge
In calculating accumulation unit values we will deduct a variable
account administrative charge from the variable subaccounts equal,
on an annual basis, to 0.25% of the daily net asset value.  This
deduction is made to compensate us for certain administrative and
operating expenses for certificates of this type.  The deduction
will be:

1.   made from each variable subaccount; and
2.   computed on a daily basis.

SURRENDER PROVISIONS

Surrender
By written request and subject to the rules below you may:

1.   surrender this certificate for the total surrender value; or
2.   partially surrender this certificate for a part of the
surrender value.

Surrender Value
The surrender value at any time will be:
<PAGE>
PAGE 15
1.   the certificate value;
2.   minus the certificate administrative charge, prorated based on
     the number of days from your last certificate anniversary to
     the date of full surrender;
3.   minus any surrender charge.

Surrender Charge
If you surrender all or part of the certificate, you may be subject
to a surrender charge.  A surrender charge applies if all or part
of the certificate value is surrendered during the first six
payment years following a purchase payment.  The surrender charge
schedule is:

     Payment Year    Surrender Charge
          1          6% of purchase payment surrendered
          2          5% of purchase payment surrendered
          3          4% of purchase payment surrendered
          4          3% of purchase payment surrendered
          5          2% of purchase payment surrendered
          6          1% of purchase payment surrendered
     Thereafter      0% of purchase payment surrendered

After the first certificate year, each year you may surrender up to
10 percent of your certificate value on the prior certificate
anniversary without incurring a surrender charge.  There is also no
surrender charge after the first certificate year on certificate
earnings defined as:

1.   the certificate value at the time of surrender; minus
2.   the sum of all purchase payments received that have not been
     previously surrendered; minus
3.   the amount of the 10% free withdrawal, if applicable.

For purposes of determining the surrender charge, surrenders will
be deemed to be taken:

1.   First, from any applicable 10% free withdrawal amount.  There
     is no surrender charge on any applicable 10% free withdrawal
     amount.

2.   Next, from certificate earnings in excess of any applicable 
     10% free withdrawal amount.  There is no surrender charge on
     certificate earnings of any applicable 10% free withdrawal
     amount.

3.   Finally, from purchase payments on a first in - first out
     basis.  There is a surrender charge on purchase payments
     depending on the payment year of the purchase payment.

Surrender Charge Calculation
The surrender charge is calculated by multiplying the amount(s)
representing purchase payments by the applicable payment year
surrender charge percentage.

For example, the surrender charge on a total surrender request in
certificate year 5 for a certificate with this history:

1.   a $10,000 purchase payment , which is now in payment year 5;
     and<PAGE>
PAGE 16
2.   a $20,000 purchase payment, which is now in payment year 2;
     and
3.   a $40,000 prior anniversary value at time of surrender; and
4.   a $42,000 certificate value when surrendered in certificate
     year 5; and
5.   no previous surrenders

is calculated this way:

Surrender Charge          Explanation
     $   0                $4,000 (10% of $40,000 prior anniversary
                          certificate value free withdrawal amount)
                          without surrender charge
     $   0                $8,000 (certificate earnings in excess of
                          applicable 10% free withdrawal amount)
                          without surrender charge
     $ 200                $10,000 times 2% (payment year 5 surrender
                          charge percentage)
     $1000                $20,000 times 5% (payment year 2 surrender
                          charge percentage)
     $1200

Rules for Surrender
All surrenders will have the following conditions:

1.   You must apply by written request or other method agreed to by
     us:

     (a)  while this certificate is in force; and
     (b)  prior to the earlier of the retirement date or the death
          of the annuitant.

2.   You must surrender an amount equal to at least $500.  Each
     variable subaccount value and the fixed account value after a
     partial surrender must be either $0 or at least $500.

3.   The amount surrendered, less any charges, will normally be
     paid to you within seven days of the receipt of your written
     request and the certificate, if required.  For surrenders from
     the fixed account, we have the right to defer payment to you
     for up to six months from the date we receive your request.

4.   For partial surrenders, if you do not specify from which
     account the surrender is to be made, the surrender will be
     made from the variable subaccounts and the fixed account in
     the same proportion as your interest in each bears to the
     certificate value.

Upon surrender for the full surrender value this certificate will
terminate.  We may require that you return the certificate to us
before we pay the full surrender value.

Suspension or Delay in Payment of Surrender
We have the right to suspend or delay the date of any surrender
payment from the variable subaccounts for any period:

1.   When the New York Stock Exchange is closed; or
2.   When trading on the New York Stock Exchange is restricted; or<PAGE>
PAGE 17
3.   When an emergency exists as a result of which:
     (a)  disposal of securities held in the variable subaccounts
          is not reasonably practical; or
     (b)  it is not reasonably practical to fairly determine the
          value of the net assets of the variable subaccounts; or
4.   During any other period when the Securities and Exchange
     Commission, by order, so permits for the protection of
     security holders.

Rules and regulations of the Securities and Exchange Commission
will govern as to whether the conditions set forth in 2 and 3
exist.

Premature Distribution Penalty Tax
You may incur a federal 10% premature distribution penalty tax. 
This may occur if you surrender all or a portion of the certificate
or settle the certificate using an annuity payment plan prior to
the close of the tax year in which you attain age 59 1/2.

ANNUITY PROVISIONS

Settlement
When settlement occurs, the certificate value will be applied to
make fixed dollar annuity payments.  The first payment will be made
as of the retirement date.  This date is shown under Certificate
Data.  Before payments begin we will require satisfactory proof
that the annuitant is alive.  We may also require that you exchange
the certificate for a supplemental contract or certificate which
provides the annuity payments.

Change of Retirement Date
You may change the retirement date shown in Certificate Data for
this certificate.  Tell us the new date by written request.  If you
select a new date, it must be at least 30 days after we receive the
written request at our home office.

The retirement date may not be later than the later of:

1.   the annuitant's 85th birthday; or
2.   the tenth certificate anniversary.

Annuity Payment Plans

You can schedule receipt of annuity payments according to one of
the Plans A through E below or another plan agreed to by us.

Plan A - This provides monthly annuity payments during the lifetime
of the annuitant.  No payments will be made after the annuitant
dies.                

Plan B - This provides monthly annuity payments during the lifetime
of the annuitant with a guarantee by us that payments will be made
for a period of at least five, ten or fifteen years.  You must
select the guaranteed period.

Plan C - This provides monthly annuity payments during the lifetime
of the annuitant with a guarantee by us that payments will be made
for a certain number of months.  We determine the number of months<PAGE>
PAGE 18
by dividing the amount applied under this plan by the amount of the
first monthly annuity payment.

Plan D - Monthly payments will be paid during the lifetime of the
annuitant and joint annuitant.  When either the annuitant or the
joint annuitant dies we will continue to make monthly payments
during the lifetime of the survivor.  No payments will be made
after the death of both the annuitant and joint annuitant.

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

Plan Selection Requirements
You may select the plan by written request to us at least 30 days
before the retirement date.  If at least 30 days before the
retirement date we have not received at our home office your
written request to select a plan, we will make fixed dollar
payments according to Plan B with payments guaranteed for ten
years.

If you select a plan that has a payment amount that is the same as
another plan having a longer guarantee period, then the plan with
the longer guarantee period will be deemed to have been chosen.

If the amount to be applied to a plan would not provide a monthly
payment of at least $50, we have the right to change the frequency
of the payment or to make a lump sum payment of the certificate
value.

Fixed Annuity
A fixed annuity is an annuity with payments that are guaranteed by
us as to dollar amount.  Fixed annuity payments remain the same. 
At settlement the fixed account certificate value will be applied
to our fixed dollar Table of Settlement Rates then in effect.  This
will be done in accordance with the payment plan chosen.  The
minimum amount payable for each $1,000 so applied is shown in Table
A on page 15.

TABLE OF SETTLEMENT RATES

The amount of the first and all subsequent monthly fixed dollar
annuity payments for each $1,000 of value applied under any payment
plan will be based on our fixed dollar Table of Settlement Rates in
effect on the settlement date.  Such rates are guaranteed to be not
less than those shown in Table A.

In addition, the amount of such fixed annuity payments will not be
less than that which would be provided if a single premium
immediate annuity certificate then offered by us to annuitants in
the same class were to be purchased with the greater of:

1.   the cash surrender value of the certificate; or
2.   95% of the accumulation value of the certificate.

The amount of such fixed annuity payments under Plans A, B and C
will depend upon the sex and the adjusted age of the annuitant on
the date of settlement.  The amount of such annuity payments under<PAGE>
PAGE 19
Plan D will depend on the sex and adjusted age of the annuitant and
the joint annuitant on the date of settlement.

Adjusted age shall be equal to the age on the nearest birthday
minus an "adjustment" depending on the calendar year of birth of
the annuitant as follows:

                                                      
     Calendar Year of Annuitant's Birth  Adjustment
     Prior to 1920                             0
     1920 through 1924                         1
     1925 through 1929                         2
     1930 through 1934                         3
     1935 through 1939                         4
     1940 through 1944                         5
     1945 through 1949                         6
     1950 through 1959                         7
     1960 through 1969                         8
     1970 through 1979                         9
     1980 through 1989                         10
     After 1989                                11<PAGE>
PAGE 20
<TABLE><CAPTION>
TABLE A - TABLE OF FIXED DOLLAR SETTLEMENT RATES
NON-QUALIFIED AND IRA CERTIFICATES

Amount of Each Monthly Fixed Dollar Annuity Payment Per $1,000 Applied
                                                                                             
     Life      5 Years    10 Years  15 Years   With
Adj. Income    Certain    Certain   Certain    Refund
Age* M    F    M     F    M    F    M    F     M    F
<S>    <C>    <C>   <C>    <C>    <C>   <C>    <C>    <C>   <C>    <C>
45   4.53 4.24 4.52  4.23 4.50 4.23 4.46 4.21  4.42 4.19
46   4.59 4.28 4.58  4.28 4.55 4.27 4.51 4.25  4.47 4.23
47   4.65 4.33 4.64  4.33 4.61 4.32 4.56 4.30  4.52 4.27
48   4.72 4.38 4.71  4.38 4.67 4.37 4.62 4.34  4.58 4.32
49   4.79 4.44 4.77  4.43 4.74 4.42 4.68 4.39  4.63 4.36

50   4.86 4.50 4.85  4.49 4.81 4.47 4.74 4.45  4.69 4.41
51   4.94 4.56 4.92  4.55 4.88 4.53 4.80 4.50  4.76 4.47
52   5.02 4.62 5.00  4.61 4.95 4.59 4.87 4.56  4.82 4.52
53   5.10 4.69 5.08  4.68 5.03 4.66 4.94 4.62  4.90 4.58
54   5.19 4.76 5.17  4.75 5.11 4.72 5.01 4.68  4.97 4.64

55   5.29 4.84 5.26  4.83 5.20 4.80 5.09 4.74  5.05 4.71
56   5.39 4.92 5.36  4.91 5.29 4.87 5.17 4.81  5.13 4.77
57   5.49 5.00 5.47  4.99 5.38 4.95 5.25 4.88  5.21 4.85
58   5.61 5.09 5.58  5.08 5.48 5.03 5.33 4.96  5.30 4.92
59   5.73 5.19 5.70  5.17 5.59 5.12 5.42 5.04  5.40 5.00

60   5.86 5.29 5.82  5.27 5.70 5.22 5.51 5.12  5.50 5.09
61   6.00 5.40 5.96  5.38 5.82 5.32 5.60 5.21  5.60 5.18
62   6.16 5.52 6.10  5.50 5.95 5.42 5.69 5.30  5.72 5.27
63   6.32 5.65 6.26  5.62 6.08 5.53 5.79 5.39  5.83 5.37
64   6.49 5.78 6.42  5.75 6.21 5.65 5.89 5.49  5.96 5.48

65   6.68 5.92 6.60  5.89 6.35 5.77 5.98 5.58  6.09 5.59
66   6.88 6.08 6.78  6.03 6.50 5.90 6.08 5.69  6.23 5.71
67   7.09 6.24 6.98  6.19 6.65 6.04 6.18 5.79  6.38 5.83
68   7.31 6.42 7.18  6.36 6.81 6.19 6.28 5.90  6.53 5.97
69   7.56 6.61 7.40  6.54 6.97 6.34 6.37 6.01  6.69 6.11

70   7.82 6.81 7.64  6.74 7.14 6.50 6.47 6.12  6.86 6.26
71   8.09 7.04 7.88  6.95 7.31 6.67 6.55 6.22  7.04 6.42
72   8.39 7.28 8.14  7.17 7.48 6.84 6.64 6.33  7.23 6.59
73   8.71 7.54 8.41  7.41 7.65 7.02 6.72 6.44  7.43 6.77
74   9.05 7.83 8.70  7.67 7.83 7.21 6.80 6.54  7.64 6.97

75   9.41 8.14 9.00  7.95 8.00 7.40 6.87 6.64  7.86 7.17
                                                                                             
/TABLE
<PAGE>
PAGE 21
<TABLE><CAPTION>
[Table A, cont'd]
Plan D - Joint and Survivor

Adj. Adjusted Age of Female Joint Annuitant
Male 10 Years  5 Years    Same      5 Years    10 Years
Age* Younger   Younger    Age       Older      Older
<S>    <C>          <C>           <C>          <C>          <C> 
45   3.80      3.89       3.99      4.10       4.19
46   3.82      3.92       4.03      4.14       4.24
47   3.85      3.95       4.07      4.18       4.29
48   3.87      3.98       4.10      4.22       4.34
49   3.90      4.02       4.15      4.27       4.39

50   3.93      4.06       4.19      4.32       4.45
51   3.96      4.09       4.23      4.38       4.51
52   4.00      4.13       4.28      4.43       4.57
53   4.03      4.18       4.33      4.49       4.64
54   4.07      4.22       4.39      4.56       4.72

55   4.11      4.27       4.45      4.62       4.79
56   4.15      4.32       4.51      4.70       4.88
57   4.19      4.37       4.57      4.77       4.96
58   4.24      4.43       4.64      4.85       5.06
59   4.28      4.49       4.71      4.94       5.16

60   4.34      4.55       4.79      5.03       5.27
61   4.39      4.62       4.87      5.13       5.38
62   4.45      4.69       4.96      5.24       5.50
63   4.51      4.77       5.06      5.35       5.64
64   4.57      4.85       5.16      5.48       5.78

65   4.64      4.94       5.27      5.61       5.93
66   4.71      5.03       5.38      5.75       6.09
67   4.79      5.13       5.51      5.90       6.27
68   4.87      5.24       5.64      6.06       6.46
69   4.96      5.35       5.78      6.24       6.66

70   5.06      5.47       5.94      6.43       6.87
71   5.16      5.60       6.10      6.63       7.11
72   5.26      5.74       6.28      6.84       7.36
73   5.38      5.89       6.47      7.08       7.62
74   5.50      6.05       6.68      7.33       7.91

75   5.63      6.22       6.90      7.60       8.22
                                                                                             
*Adjusted Age of annuitant.  Refer to the explanation of adjusted age on page 22.
M = Male  F = Female
                                                                                             
The table above is based on the "1983 Individual Annuitant Mortality Table A" assuming an
interest rate of 4% per year compounded annually.  Settlement rates for any age, or any
combination of age and sex not shown above, will be calculated on the same basis as those
rates shown in the table above.  Such rates will be furnished by us upon request.  Amounts
shown in the table below are based on an assumed interest rate of 4% per year compounded
annually.
</TABLE>
<TABLE><CAPTION>
                                                                                             
Plan E - Dollar Amount of Each Monthly Fixed Dollar Annuity Payment Per $1,000 Applied
                                                                                             
Years     Monthly         Years     Monthly    Years     Monthly
Payable   Payment         Payable   Payment    Payable   Payment
<S>           <C>                 <C>          <C>          <C>           <C> 
10        $10.06          17        $6.71      24        $5.35
11          9.31          18         6.44      25         5.22
12          8.69          19         6.21      26         5.10
13          8.17          20         6.00      27         5.00
14          7.72          21         5.81      28         4.90
15          7.34          22         5.64      29         4.80
16          7.00          23         5.49      30         4.72
</TABLE>
<PAGE>
PAGE 1
Group Deferred Variable Annuity Application

1.   Full legal name of applicant ABC Trust Company            
     [x]  corporation
     [ ]                                                       
     Principal Office 456 Any street Anycity Anystate zzzzz    
                          (Street)    (City)  (State)  (Zip)

2.   Nature of Business   Trustee under Trust Agreement dated xx-xx-
                          xx by and between IDS Life Insurance
                          Company of New York and ABC Trust Company

3.   If clients of subsidiary or affiliate companies (companies
     under common control through stock ownership, contract, or
     otherwise) are to be covered, list legal names and addresses
     of such companies and the nature of this business.

                                                                  
                                                                  
                                                                  

4.   Requested Effective Date: November 1, 1991                   

5.   Eligibility Requirements:      Clients of Shearson Lehman
                                    Brothers, Inc.

6.   Remarks:
                                                                  
                                                                  

I/we hereby acknowledge receipt of current prospectuses for the
variable annuity and any funds involved.

Dated at Anycity                , State of Anystate              ,
the    29th     day of October  , 1991.
Witness I.M. Witness           Applicant ABC Trust Company
                                    by   I.M. Trust Officer
                                 Title   Trust Officer 

<PAGE>
PAGE 1
IDS Life Insurance Company
of New York
Box 5144
Albany, New York  12055

SYMPHONY Variable Annuity Group Enrollment Application

1. Full Name of Annuitant (First, Middle Initial, Last)
     John Doe

2. Address (Street Address or P.O. Box, City, State, Zip)
     123 Anystreet
     Anycity, Anystate zzzzz

Phone Number
     (111) 111-1111

3. Sex  M   F    4.  Date of Birth  5.  Social Security Number
        x            10-1-56   111-11-1111
        
6.  Beneficiary (Primary)      Relationship
     Mary Doe             Spouse    

Contingent Beneficiary (if any)     Relationship


7.   Full Name of Certificate Owner*
     (If other than Annuitant or if Joint Spousal Ownership)
     *For joint spousal owners, insert information about both
     owners including both Social Security Numbers.  Circle the
     Social Security Number to be used for tax-reporting purposes.

Address (Street Address or P.O. Box, City, State, Zip)
     
Relationship to Annuitant

Social Security Number                            Date of Birth


8.   Will the annuity applied for replace any existing insurance or
     annuity?          Yes   X  No
     (If yes, send applicable replacement requirements)


9.   Check the applicable plan:
      X   Non-Qualified Annuity
          Individual Retirement Account (IRA)
          Tax Qualified (list type)                             
     If IRA:
              Regular -- Amount for previous year   $             
                                      -- Amount for current year  $ 
              Rollover IRA
         Trustee to Trustee transfer from:                 
<PAGE>
PAGE 2
10.  Certificate Provisions:
     Settlement Age  65 
     Single Purchase Payment $10,000   
     *Payment Allocation
      10 % Money Market                   10 % Equity Index
      10 % Intermediate High Grade        10 % Growth and Income
      10 % Diversified Strategic          10 % Appreciation
          Income                          30 % Fixed Account
      10 % Equity Income                     % Other
                                             % Other
     *Must be whole numbers, and, for non-quaified annuities, must
     result in at least $500 allocated to any variable subaccount
     or to the fixed account.

11.  Remarks, Explanations and Special Instructions
     (Including special mailing instructions)

     6A 393776P-1

It Is Agreed That:
1.   All statements and answers given above are true and complete
     to the best of my/our knowledge.
2.   Only an officer of IDS Life Insurance Company of New York can
     modify any annuity certificate or waive any requirement in
     this application.
3.   If joint spousal owners are named, ownership will be in joint
     tenancy with right of survivorship unless specified otherwise
     in Item 11 above.
4.   I/we hereby acknowledge receipt of current prospectuses for
     the variable annuity and any funds involved.
5.   I/we understand that earnings and values, when based on the
     investment experience of a variable fund, portfolio, account
     or subaccount, are not guaranteed and may both increase and
     decrease.

Signatures

 AnyCity, AnyState    John Doe                                    
Location  Signature of    Signature of
City/State    Proposed Annuitant  Certificate Owner
                          (if other than
                          proposed annuitant)

 October 31, 1991     I.M. Agent                                   
Date      Signature of    Signature of
          Licensed Agent  Joint Certificate
                          Owner (if any) 
                     
<PAGE>
PAGE 1
October 14, 1992



Securities and Exchange Commission
450 Fifth Street, NW
Washington DC  20549-1004

ATTN:     Ms. Joyce M. Pickholz

RE:       IDS LIFE OF NEW YORK ACCOUNT SLB FORM N-4 REGISTRATION
          STATEMENT NO. 33-45776/811-6560

Dear Commissioners:

IDS Life of New York Account SLB, the Registrant, has filed Pre-
effective Amendment No. 1, dated October 14, 1992, to the above-
referenced Form N-4 Registration Statement.  Pursuant to Rule 461,
the Registrant, IDS Life of New York Account SLB, now respectfully
requests that the effective date of the above-referenced
Registration be accelerated and that the Registration Statement be
declared effective on October 21, 1992, or as soon as practicable
thereafter.

Yours truly,


IDS Life of New York Account SLB
(Registrant)


By:  /s/ Michael B. Carlin
     Michael B. Carlin
     General Counsel and Secretary<PAGE>
PAGE 2
October 7, 1992



Board of Directors
IDS Life Insurance Company of New York
20 Madison Avenue Extension
Albany, New York  12203

Gentlemen:

As General Counsel of IDS Life Insurance Company of New York (the
Company), I am familiar with its legal affairs and with IDS Life of
New york Account SLB (the Account), which is a separate account of
the Company established by the Company's Board of Directors
pursuant to Section 4240 of the New York Insurance Laws.  I am
familiar with the Registration Statement on Form N-4 and Pre-
effective Amendment No. 1 thereto (File No. 33-45776/811-6560) (the
Registration Statement), filed by the Company on behalf of Account
SLB with the Securities and Exchange Commission with respect to the
Account pursuant to Group Flexible Premium Deferred Fixed and
Variable Annuities and related Certificates (collectively, the
Contracts).

I have made such examination of law and examined such documents and
records as in my judgment are necessary and appropriate to enable
me to express the following opinions.  I am of the opinion that:

1.   The Company is duly incorporated, validly existing and in good
     standing under the laws of the State of New York, and is duly
     licensed or qualified to do business in New York and North
     Dakota wherein the business transacted by it requires such
     licensing or qualification.  The Company has all corporate
     powers required to carry on its business as now conducted and
     to issue the Contracts.

2.   The Account is a separate account of the Company, duly
     established and validly existing pursuant to New York law.

3.   The Contracts, when issued, offered and sold in accordance
     with the prospectus contained in the aforesaid Registration
     Statement and, upon reliance of local law, will be legal and
     binding obligations of the Company in accordance with their
     terms.

4.   There is no limitation as to the interests in the Account that
     may be issued.

5.   There is no pending or unthreatened litigation claims or
     assessments (including any unasserted claims or assessments)
     against the Company.

Please be advised you are correct in your understanding that I will
advise and consult with you concerning questions of disclosure and
the applicable requirements of Statements of Financial Accounting
Standards No. 5 if, and when, in the course of performing legal
services for the Company or the Account with respect to a matter
recognized by me to involve an unasserted claim or assessment that
may require financial statement disclosure or consider disclosure<PAGE>
PAGE 3
of any such possible claim or assessment in your financial
statements.  You may furnish a copy of this letter to your
independent accountants.

I hereby consent to the filing of this opinion as an exhibit to the
Registration Statement.

Sincerely,



/s/ Michael B. Carlin
Michael B. Carlin
General Counsel and Secretary 

<PAGE>
PAGE 1




                    Consent of Independent Auditors







We consent to the use of our reports dated February 3, 1995 on the
financial statements and financial statement schedules of IDS Life
Insurance Company of New York and our report dated March 17, 1995
on the financial statements of IDS Life of New York Account SBS in
Post-Effective Amendment No. 5 to the Registration Statement (Form
N-4 No. 33-45776) being filed under the Securities Act of 1933 and
the Investment Company Act of 1940.









Ernst & Young LLP
Minneapolis, Minnesota
April 26, 1995

<PAGE>
PAGE 1 
<TABLE>
<CAPTION>

IDS LIFE INSURANCE COMPANY OF NEW YORK
SCHEDULE I - SUMMARY OF INVESTMENTS
OTHER THAN INVESTMENTS IN RELATED PARTIES ($ thousands)
AS OF DECEMBER 31, 1994

Column A                                     Column B        Column C        Column D
                                                                           Amount at which
Type of Investment                             Cost            Value       shown in the
                                                                           balance sheet
<S>                                       <C>             <C>             <C>
Fixed maturities:
  Held to maturity:
    United States Government and
     government agencies and
     authorities (a)                      $      23,491   $      21,150   $      23,491
    States, municipalities and
      political subdivisions                          -               -               -
    All other corporate bonds                   662,992         631,930         662,992

          Total held to maturity                686,483   $     653,080         686,483

  Available for sale:
    United States Government and
     government agencies and
     authorities (a)                      $     145,711   $     135,141   $     135,141
    States, municipalities and
      political subdivisions                        104             105             105
    All other corporate bonds                   328,784         319,857         319,857

          Total available for sale              474,599   $     455,103         455,103

Mortgage loans on real estate                   164,916     XXXXXXXXXX          164,916
Policy loans                                     14,899     XXXXXXXXXX           14,899
Other investments                                 1,524                           1,524

          Total investments               $   1,342,421     XXXXXXXXXX    $   1,322,925



(a) - Includes mortgage-backed securities with a cost and market value of $23,093 and $20,768,
      respectively.

(b) - Includes mortgage-backed securities with a cost and market value of $135,711 and $125,276,
      respectively.

</TABLE>
<PAGE>
PAGE 2
<TABLE>
<CAPTION>

IDS LIFE INSURANCE COMPANY OF NEW YORK
SCHEDULE III - SUPPLEMENTARY INSURANCE INFORMATION ($ thousands)
FOR THE YEAR ENDED DECEMBER 31, 1994

Column A          Column B      Column C      Column D      Column E      Column F

Segment           Deferred       Future       Unearned    Other policy    Premium
                   policy        policy       premiums     claims and     revenue
                 acquisition    benefits,                   benefits
                    cost         losses,                    payable
                               claims and
                                  loss
                                expenses
<S>              <C>           <C>           <C>          <C>             <C>
Annuities        $   61,442    $1,087,367    $    -       $  1,348        $   - 

Life, DI and
Long-term Care
Insurance            38,636       168,417         -          1,869         7,846

Total            $  100,078    $1,255,784    $    -       $  3,217        $7,846

Column A          Column G      Column H      Column I      Column J      Column K

Segment             Net         Benefits,   Amortization     Other        Premiums
                 investment      claims,    of deferred    operating      written
                   income      losses and      policy      expenses
                               settlement   acquisition           
                                expenses        costs

Annuities        $   92,583    $       81    $  9,392     $   4,765          N/A

Life, DI and
Long-term Care
Insurance            15,560        10,214       3,602         3,594          N/A

Total            $  108,143    $   10,295    $ 12,994     $   8,359          N/A

/TABLE
<PAGE>
PAGE 3
<TABLE>
<CAPTION>

IDS LIFE INSURANCE COMPANY OF NEW YORK
SCHEDULE III - SUPPLEMENTARY INSURANCE INFORMATION ($ thousands)
FOR THE YEAR ENDED DECEMBER 31, 1993

Column A          Column B      Column C      Column D      Column E      Column F

Segment           Deferred       Future       Unearned    Other policy    Premium
                   policy        policy       premiums     claims and     revenue
                 acquisition    benefits,                   benefits
                    cost         losses,                    payable
                               claims and
                                  loss
                                expenses
<S>              <C>           <C>           <C>          <C>             <C>
Annuities        $   53,300    $1,059,005    $    -       $  1,707        $   - 

Life, DI and
Long-term Care
Insurance            34,591       160,962         -            640         7,110

Total            $   87,891    $1,219,967    $    -       $  2,347        $7,110

Column A          Column G      Column H      Column I      Column J      Column K

Segment             Net         Benefits,   Amortization     Other        Premiums
                 investment      claims,    of deferred    operating      written
                   income      losses and      policy      expenses
                               settlement   acquisition           
                                expenses        costs

Annuities        $   93,943    $      103    $  7,707     $   4,459          N/A

Life, DI and
Long-term Care
Insurance            16,204         6,733       2,727         3,193          N/A

Total            $  110,147    $    6,836    $ 10,434     $   7,652          N/A

</TABLE>
<PAGE>
PAGE 4
<TABLE>
<CAPTION>

IDS LIFE INSURANCE COMPANY OF NEW YORK
SCHEDULE III - SUPPLEMENTARY INSURANCE INFORMATION ($ thousands)
FOR THE YEAR ENDED DECEMBER 31, 1992

Column A          Column B      Column C      Column D      Column E      Column F

Segment           Deferred       Future       Unearned    Other policy    Premium
                   policy        policy       premiums     claims and     revenue
                 acquisition    benefits,                   benefits
                    cost         losses,                    payable
                               claims and
                                  loss
                                expenses
<S>              <C>           <C>           <C>          <C>             <C>
Annuities        $   45,708    $  966,645    $    -       $  1,130        $   - 

Life, DI and
Long-term Care
Insurance            31,561       155,270         -            935         6,282

Total            $   77,269    $1,121,915    $    -       $  2,065        $6,282

Column A          Column G      Column H      Column I      Column J      Column K

Segment             Net         Benefits,   Amortization     Other        Premiums
                 investment      claims,    of deferred    operating      written
                   income      losses and      policy      expenses
                               settlement   acquisition           
                                expenses        costs

Annuities        $   85,375    $       84    $  4,551     $   1,802          N/A

Life, DI and
Long-term Care
Insurance            16,696         6,899       3,586         4,601          N/A

Total            $  102,071    $    6,983    $  8,137     $   6,403          N/A

</TABLE>
<PAGE>
PAGE 5
<TABLE>
<CAPTION>

IDS LIFE INSURANCE COMPANY OF NEW YORK
SCHEDULE IV - REINSURANCE ($ thousands)
FOR THE YEARS ENDED DECEMBER 31, 1994, 1993 AND 1992

Column A                     Column B         Column C         Column D         Column E       Column F

                           Gross amount    Ceded to other    Assumed from         Net         % of amount
                                              companies     other companies      Amount     assumed to net
<S>                       <C>              <C>              <C>              <C>                 <C>   
For the year ended
  December 31, 1994

Life insurance
  in force                $     3,602,888  $       162,956  $       447,317  $     3,887,249     11.51%

Premiums:
  Life insurance
   & annuities            $         2,219  $           209  $           --   $         2,010      0.00%
  DI &
   long-term care
   insurance                        5,919               83              --             5,836      0.00%
Total premiums            $         8,138  $           292  $             0  $         7,846      0.00%


For the year ended
  December 31, 1993

Life insurance
  in force                $     2,933,830  $       172,973  $       512,555  $     3,273,412     15.66%

Premiums:
  Life insurance
   & annuities            $         2,250  $           187  $           --   $         2,063      0.00%
  DI &
   long-term care
   insurance                        5,140               93              --             5,047      0.00%
Total premiums            $         7,390  $           280  $             0  $         7,110      0.00%


For the year ended
  December 31, 1992

Life insurance
  in force                $     2,192,426  $       179,976  $       592,792  $     2,605,242     22.75%

Premiums:
   Life insurance
   & annuities            $         2,251  $           208  $           --   $         2,043      0.00%
  DI &
   long-term care
   insurance                        4,386              147              --             4,239      0.00%
Total premiums            $         6,637  $           355  $             0  $         6,282      0.00%

</TABLE>
<PAGE>
PAGE 6
<TABLE>
<CAPTION>

IDS LIFE INSURANCE COMPANY OF NEW YORK
SCHEDULE V - VALUATION AND QUALIFYING ACCOUNTS ($ thousands)
FOR THE YEARS ENDED DECEMBER 31, 1994, 1993 AND 1992

Column A          Column B       Column C                           Column D         Column E

                                 Additions
                 Balance at   --------------       Charged to
Description       Beginning      Charged to      Other Accounts-   Deductions-     Balance at End
                  of Period   Costs & Expenses      Describe        Describe         of Period
<S>                 <C>              <C>                <C>             <C>           <C>
For the year ended
  December 31, 1994
- ------------------------------
Reserve for
 Mortgage Loans     $445             $0                 $0              $0              $445
Reserve for
 Fixed Maturities   $1,652           $(1,652)           $0              $0              $0

For the year ended
  December 31, 1993
- ------------------------------
Reserve for
 Mortgage Loans     $500             ($55)              $0              $0              $445
Reserve for
 Fixed Maturities   $1,159           $493               $0              $0            $1,652

For the year ended
  December 31, 1992
- ------------------------------
Reserve for
 Mortgage Loans     $200             $300               $0              $0              $500
Reserve for
 Fixed Maturities   $3,737          ($2,578)            $0              $0            $1,159

</TABLE>
<PAGE>
PAGE 7







                    Report of Independent Auditors




The Board of Directors
IDS Life Insurance Company of New York

We have audited the financial statements of IDS Life Insurance
Company of New York (a wholly owned subsidiary of IDS Life
Insurance Company) as of December 31, 1994 and 1993, and for each
of the three years in the period ended December 31, 1994, and have
issued our report thereon dated February 3, 1995 (included
elsewhere in this Registration Statement).


Our audits also included the financial statements schedules I, III,
IV and V included elsewhere in this Registration Statement.  These
schedules are the responsibility of the Company's management.  Our
responsibility is to express an opinion based on our audits.

In our opinion, the financial statement schedules referred to
above, when considered in relation to the basic financial
statements taken as a whole, present fairly, in all material
respects, the information set forth therein.



Ernst & Young LLP
Minneapolis, Minnesota
February 3, 1995

<PAGE>
PAGE 1
Performance Calculations

NON-MONEY MARKET SUBACCOUNTS

TOTAL RETURN
The total return is the percentage change between the initial
investment at the beginning of the period and the total value of
the investment at the end of the period.

     Total Return = Ending Total Value - Initial Investment
                               Initial Investment

The ending total value includes income and capital gains
distributions treated as reinvested.  It also reflects deductions
for the contract administrative charge, variable account
administrative charge and the mortality and expense risk charge.

AVERAGE ANNUAL TOTAL RETURN
The average annual total return of a subaccount reflects the
average annual compounded rate of return of a hypothetical
investment over a period of one, five and ten years (or, if less,
up to the life of the subaccount), calculated according to the
following formula:

                     P(1+T)n = ERV

     where:    P     =    a hypothetical initial payment of $1000.
               T     =    average annual total return.
               n     =    number of years.
             ERV     =    ending redeemable value of a hypothetical
                          $1,000 payment made at the beginning of
                          the one, five or ten year periods (or
                          fractional portion thereof).

The average annual total return without surrender charge reflects
the deduction of the contract administrative charge, variable
account administrative charge and mortality and expense risk
charge.

The average annual total return with surrender charge reflects the
above deductions and assumes the contract owner surrenders the
entire contract at the end of the one, five and ten year periods.


<TABLE> <S> <C>
<PAGE>
<ARTICLE>                             6
<CIK>                        0000883963 
<NAME> IDS Life of New York Account SBS  
<CURRENCY>                  U.S. DOLLAR
<FISCAL-YEAR-END>           DEC-31-1994            
<PERIOD-START>              JAN-01-1994            
<PERIOD-END>                DEC-31-1994            
<PERIOD-TYPE>                      YEAR
<EXCHANGE-RATE>                       1
<INVESTMENTS-AT-COST>          16462354
<INVESTMENTS-AT-VALUE>         15792701
<RECEIVABLES>                       119
<ASSETS-OTHER>                        0            
<OTHER-ITEMS-ASSETS>                  0
<TOTAL-ASSETS>                 15792820
<PAYABLE-FOR-SECURITIES>              0
<SENIOR-LONG-TERM-DEBT>               0
<OTHER-ITEMS-LIABILITIES>       (19651)
<TOTAL-LIABILITIES>             (19651)
<SENIOR-EQUITY>                       0
<PAID-IN-CAPITAL-COMMON>              0
<SHARES-COMMON-STOCK>          15979633
<SHARES-COMMON-PRIOR>          10029548
<ACCUMULATED-NII-CURRENT>             0
<OVERDISTRIBUTION-NII>                0
<ACCUMULATED-NET-GAINS>               0
<OVERDISTRIBUTION-GAINS>              0
<ACCUM-APPREC-OR-DEPREC>              0
<NET-ASSETS>                   15773169
<DIVIDEND-INCOME>                461338
<INTEREST-INCOME>                     0
<OTHER-INCOME>                        0
<EXPENSES-NET>                 (212819)
<NET-INVESTMENT-INCOME>          248519
<REALIZED-GAINS-CURRENT>        (78366)
<APPREC-INCREASE-CURRENT>      (861104)
<NET-CHANGE-FROM-OPS>          (690951)
<EQUALIZATION>                        0
<DISTRIBUTIONS-OF-INCOME>             0
<DISTRIBUTIONS-OF-GAINS>              0 
<DISTRIBUTIONS-OTHER>                 0
<NUMBER-OF-SHARES-SOLD>         6977404
<NUMBER-OF-SHARES-REDEEMED>   (1027319)
<SHARES-REINVESTED>                   0
<NET-CHANGE-IN-ASSETS>          5368662
<ACCUMULATED-NII-PRIOR>               0
<ACCUMULATED-GAINS-PRIOR>             0
<OVERDISTRIB-NII-PRIOR>               0
<OVERDIST-NET-GAINS-PRIOR>            0
<GROSS-ADVISORY-FEES>                 0
<INTEREST-EXPENSE>                    0
<GROSS-EXPENSE>                (212819)
<AVERAGE-NET-ASSETS>           13088838
<PER-SHARE-NAV-BEGIN>                 0
<PER-SHARE-NII>                       0
<PER-SHARE-GAIN-APPREC>               0

<PER-SHARE-DIVIDEND>                  0
<PER-SHARE-DISTRIBUTIONS>             0
<RETURNS-OF-CAPITAL>                  0
<PER-SHARE-NAV-END>                   0            
<EXPENSE-RATIO>                       0
<AVG-DEBT-OUTSTANDING>                0
<AVG-DEBT-PER-SHARE>                  0

</TABLE>

<TABLE> <S> <C>
<PAGE>
<ARTICLE>                                        7
<CIK>                                   0000883963 
<NAME>  IDS Life Insurance Company of New York
<MULTIPLIER>                                  1000
<CURRENCY>                             U.S. DOLLAR
<FISCAL-YEAR-END>        DEC-31-1993   DEC-31-1994
<PERIOD-START>           JAN-01-1993   JAN-01-1994
<PERIOD-END>             DEC-31-1993   DEC-31-1994
<PERIOD-TYPE>                   YEAR          YEAR 
<EXCHANGE-RATE>                    1             1
<DEBT-HELD-FOR-SALE>               0        455103
<DEBT-CARRYING-VALUE>        1171023        686483
<DEBT-MARKET-VALUE>          1240593        653080
<EQUITIES>                       190           135
<MORTGAGE>                    123337        164916
<REAL-ESTATE>                      0             0
<TOTAL-INVEST>               1309551       1322925
<CASH>                            0           5262
<RECOVER-REINSURE>               246             3
<DEFERRED-ACQUISITION>         87891        100078
<TOTAL-ASSETS>               1801850       1957574
<POLICY-LOSSES>              1219967       1255784
<UNEARNED-PREMIUMS>                0             0
<POLICY-OTHER>                     0             0
<POLICY-HOLDER-FUNDS>           2347          3217
<NOTES-PAYABLE>                    0             0
<COMMON>                        2000          2000
              0             0
                        0             0
<OTHER-SE>                    158459        169721
<TOTAL-LIABILITY-AND-EQUITY> 1801850       1957574
                      7110          7846
<INVESTMENT-INCOME>           110147        108143
<INVESTMENT-GAINS>              1334           957
<OTHER-INCOME>                 12538         16170
<BENEFITS>                     75824         75313
<UNDERWRITING-AMORTIZATION>    10434         12994
<UNDERWRITING-OTHER>            7652          8359
<INCOME-PRETAX>                37219         36449
<INCOME-TAX>                   13335         12794
<INCOME-CONTINUING>            23884         23655
<DISCONTINUED>                     0             0
<EXTRAORDINARY>                    0             0
<CHANGES>                          0             0      
<NET-INCOME>                   23884         23655
<EPS-PRIMARY>                      0             0
<EPS-DILUTED>                      0             0
<RESERVE-OPEN>                  1026           450
<PROVISION-CURRENT>             8180          9789
<PROVISION-PRIOR>                  0             0
<PAYMENTS-CURRENT>              8756          8537
<PAYMENTS-PRIOR>                   0             0
<RESERVE-CLOSE>                  450          1702
<CUMULATIVE-DEFICIENCY>            0             0

</TABLE>


© 2022 IncJournal is not affiliated with or endorsed by the U.S. Securities and Exchange Commission