EXHIBIT (4)(P)



 EXHIBIT (4)(p) 

FORM OF POLICY RIDER (RETIREMENT INCOME CHOICE 1.4) 








									
	



				  
  

Home Office:
		
		 		4333 Edgewood Road N.E.		 
				Cedar Rapids, Iowa 52499		 
		 		(319)355-8511		 
			A Stock Company (Hereafter called the Company, we, our or us)						

 RETIREMENT INCOME CHOICE RIDER 

This rider is issued as a part of the policy (contract) to which it is attached. Policy refers to the individual policy if the rider is attached to an
individual annuity or the group certificate if the rider is attached to a group annuity. 
 All provisions of the policy that do not conflict with this
rider apply to this rider. In the event of any conflict between the provisions of this rider and the provisions of the policy, the provisions of this rider shall prevail over the provisions of the policy. 

Rider Data Specification 
  

													
			Policy Number:  		 		12345		 				
			Rider Date:  				07/01/2009		 				
			Growth Rate Percentage:  		 		5.00%		 				
							
			Rider Fee Percentages:  										
			Designated Allocation Group A:  		 		1.25%		 				
			Designated Allocation Group B:  				0.90%		 				
			Designated Allocation Group C:  		 		0.40%		 				
							
													
			Annuitant:  		 		John Doe		 				
							
													
			Annuitant’s Issue Age/Sex:  		 		35 / Male		 				

 ARTICLE I 
 You may
cancel this rider on the close of business before midnight of the thirtieth calendar day after you received it and no rider fees will be assessed. 
 If you
elect this rider, 100% of your policy value must be in one or more of the designated investment options. 
 You can generally transfer between the
designated investment options as permitted under your policy; however, you cannot make transfers as provided for in the policy to a non-designated investment option while this rider is in force. If you wish to make a transfer to a non-designated
investment option, this rider must be terminated, as described in Article IV, prior to making the transfer. 
 DEFINITIONS: 

Terms used that are not defined in this rider shall have the same meaning as those in your policy. 

Designated Investment Options 
 Investment options
authorized for use with this rider and identified by us as designated investment options. 
 Excess Withdrawal 

The excess of a gross partial withdrawal over the rider withdrawal amount remaining prior to the withdrawal, if any. 

Gross Partial Withdrawal 
 The amount by which will be
deducted from your policy value as a result of each partial withdrawal. 

  

					
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 ARTICLE I CONTINUED 

Rider Anniversary 
 The anniversary of the rider date. 

Rider Fee 
 The fees charged for the benefits under this
rider. The fees will be charged on a rider quarterly basis by the Company. 
 Rider Monthiversary 

The same day of the month as the rider date, or the next business day if our Administrative Office or the New York Stock Exchange are closed. 

Rider Quarter 
 The last business day of each rider
quarter, or the next business day if our Administrative Office or the New York Stock Exchange are closed. 
 Rider Withdrawal Amount 

The maximum amount that can be withdrawn from the policy each rider year without causing an excess withdrawal under the terms of this rider and thus reducing
the withdrawal base. This amount will change if the withdrawal base changes. 
 Rider Year 

Each twelve-month period following the rider date. 
 Valuation
Period 
 The period of time from one determination of the value of a subaccount to the next. Such determinations are made when the value of the assets
and liabilities of each subaccount is calculated. This is generally the close of business on each day on which the New York Stock Exchange is open. 

Withdrawal Base 
 The amount used to calculate the rider
withdrawal amount and the rider fee. This amount cannot be taken as a lump sum. 
 ARTICLE II 

RIDER FEES 
 The rider fee is deducted on each rider
quarter in arrears. The fee is calculated and stored at issue and at each subsequent rider quarter for the upcoming quarter. The rider fee percentage will not change during the first five rider years, and will only change thereafter due to an
automatic step-up. You will be notified of any increase in the rider fee percentage. A portion of this fee will also be deducted when the rider is terminated based on the number of days that have elapsed since the previous rider quarter. 

The stored fee will be adjusted for new deposits, transfers among designated investment options and excess withdrawals made during the rider quarter. 

Fees will be calculated and stored on the day the rider is issued and at the beginning of each rider quarter. They will be deducted automatically from each
investment option on a pro rata basis at the end of each rider quarter. The annual fee percentages for each designated allocation group are shown on page 1, in the Rider Data Specification section. 

The quarterly fee is calculated as follows: 
 Multiply
(1) by (2) divided by (3) multiplied by (4). 
  

	1)	Withdrawal Base; 

  

	2)	Sum of each designated allocation group rider fee percentage multiplied by the applicable designated allocation group value; 

  

	3)	Total policy value; 

  

	4)	Number of days remaining in the rider quarter divided by the number of days within the applicable rider year. 


Please see the Appendix attached to this rider which illustrates how the rider fee is calculated. 

  

					
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 ARTICLE III 

GUARANTEED LIFETIME WITHDRAWAL BENEFIT 
 Under this rider,
we guarantee that you can receive up to the rider withdrawal amount each rider year, regardless of the policy value, (either through withdrawals or payments, where payments are equal to the rider withdrawal amount if your policy value equals zero)
until the annuitant’s death. 
 The withdrawal percentage is determined by the attained age (age at last birthday) of the annuitant at the time of the
first withdrawal of any amount from the policy value taken on or after the rider anniversary following the annuitant’s [59th] birthday. Once the withdrawal percentage is established, it may only be changed by an upgrade or automatic step-up and
redetermined at that time. Upon automatic step-up, the withdrawal percentage will be reset based on the attained age at the time of the automatic step-up. The withdrawal percentages are shown in the table below. 

 

													
	 	 	 	 	 	 	 	 	 	 	Withdrawal	 	 
	 Attained Age
	 	 	 	Percentage
	 	 	 	 	 	 	 	 	 	 	 	 	 
	 	 	 0 - 58
	 	 	 		 	 	 	0.0%	 	 
	 	 	 59 - 69
	 	 	 		 		 	4.0%	 	 
	 	 	 70 - 79
	 	 	 		 		 	5.0%	 	 
	 	 	 80 +
	 	 	 		 	 	 	6.0%	 	 

 If the annuitant is not yet [59] on the rider date, the withdrawal percentage will be zero until the rider anniversary
following the annuitant’s [59th] birthday. Withdrawals prior to age 59 1/2 will be subject to the 10% penalty tax. 
 Withdrawals will reduce the
policy value of the policy to which this rider is attached. If the policy value equals zero, you cannot make subsequent premium payments and all other policy features, benefits and guarantees are no longer available. Also, if the policy value equals
zero, you will need to request payments by selecting the amount and frequency in accordance with the policy provisions to which this rider attaches, equal to the rider withdrawal amount. Once the payment amount and frequency are established, they
cannot be changed and no additional withdrawals will be allowed. 
 ISSUE AGE AND SURVIVAL 

The benefits under this rider depend on the annuitant being alive at the time of withdrawal and the amount of the benefit depends on the issue age of the
annuitant. Proof of survival and the issue ages may be required by the Company. 
 If the annuitant’s age has been misstated, this rider’s fees
and benefits will be adjusted to the amounts which would have been calculated for the correct age. However, if this rider would not have been issued had the age not been misstated, the rider is treated as if it never existed, and any fees charged
for this rider would be returned. If withdrawals under the provisions of the rider have already commenced and the misstatement caused the rider withdrawal amount to be overstated, any withdrawal in excess of the correct rider withdrawal amount will
be considered an excess withdrawal and will impact the withdrawal base and rider withdrawal amount. If overpayments occurred when the sum of the accumulated values in all the investment options was zero, the amount of that overpayment will be
deducted from one or more future payments until this amount is paid in full. 
 RIDER WITHDRAWAL AMOUNT 

The rider withdrawal amount will be equal to the greater of 1) and 2), where: 
  

	1)	is the withdrawal percentage multiplied by the withdrawal base; 

  

	2)	is an amount equal to the minimum required distribution amount, if any. Prior to the 1st rider anniversary, this amount is based on the initial policy value on the rider date. After this time, the minimum required
distribution is calculated based on the rules established by the IRS. The minimum required distribution may only be used if all of the following are true: 

  

	 	A)	the policy to which this rider is attached is a tax-qualified policy for which IRS minimum required distributions are required, 

  

	 	B)	the minimum required distributions do not start prior to the annuitant’s attained age 70 1/2, 

  

	 	C)	the minimum required distributions are based on either the Uniform Lifetime table or the Joint Life and Last Survivor Expectancy table, 


 

	 	D)	the minimum required distributions are based on age of the living annuitant. The minimum required distributions can not be based on the age of someone who is deceased, 


 

	 	E)	the minimum required distributions are based only on the policy to which this rider is attached, and 

  

	 	F)	the minimum required distributions are only for the current rider year. Amounts carried over from past rider years are not considered. 


  

					
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 ARTICLE III CONTINUED 

If any of the above are not true, then 2) is equal to zero and it is not available as a rider withdrawal amount. 

If you withdraw less than the rider withdrawal amount in a rider year, the unused portion cannot be carried over to the next rider year. 

WITHDRAWAL BASE 
 The withdrawal base is used to calculate
the rider withdrawal amount. On the rider date, the initial withdrawal base is equal to the policy value (less any premium enhancements if the rider is added in the first policy year). During any rider year, the withdrawal base is increased by
subsequent premium payments (not including premium enhancements, if any), and is reduced for excess withdrawals. 
 On each rider anniversary, the
withdrawal base will be set to the greatest of: 
  

	 	1)	The current withdrawal base; 

  

	 	2)	The policy value on the rider anniversary; 

  

	 	3)	The highest policy value on a rider [monthiversary] for the current rider year; or 

  

	 	4)	The current withdrawal base immediately prior to rider anniversary processing increased by the growth rate percentage. 


Item 3) above will be zero if there have been any excess withdrawals in the current rider year. Item 4) above will be zero after the [10th] rider
anniversary or if there have been any withdrawals in the current rider year. 
 AUTOMATIC STEP-UP FEATURE 

The rider receives an automatic step-up on the rider anniversary if the withdrawal base is set equal to the policy value or the highest policy value on a rider
[monthiversary.] This feature does not require the termination of the existing rider. This rider will continue with the same rider date and features. The rider fee and withdrawal percentages may be changed due to an automatic step-up, but there will
be no increase in the rider fee percentage during the first [five] rider years. Following the [fifth] rider anniversary, the rider fee percentage may be increased due to an automatic step-up, but will not increase more than [0.75%] from the initial
rider fee percentages shown on page 1. 
 You have the right to reject an automatic step-up within [30] days following a rider anniversary, if the rider fee
percentage increases. If you reject an automatic step-up, you must notify us in a manner which is acceptable to us, however you are eligible for future automatic step-ups. Changes as a result of the automatic step-up feature will be reversed. Any
increase in the rider fee or withdrawal percentages will also be reversed. 
 WITHDRAWAL BASE ADJUSTMENTS 

Gross partial withdrawals, taken in a rider year, less than or equal to the rider withdrawal amount will not reduce the withdrawal base. Excess withdrawals
will reduce the withdrawal base by the withdrawal base adjustment. The withdrawal base adjustment is the greater of 1) and 2), where: 
  

	1)	is the excess withdrawal amount; and 

  

	2)	is the result of (A multiplied by B), divided by C, where: 

  

	 	A)	is the excess withdrawal; 

  

	 	B)	is the withdrawal base prior to the excess withdrawal amount; and 

  

	 	C)	is the policy value after the rider withdrawal amount has been withdrawn, but prior to the withdrawal of the excess withdrawal amount. 


  

					
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 ARTICLE IV 

CONTINUATION 
 In the case of spousal joint owners where
one spouse is the annuitant, if the spouse who is not the annuitant dies and the surviving spouse is the sole beneficiary, the surviving spouse may elect to continue the policy and rider. In the case of spousal joint owners where one spouse is the
annuitant, if the spouse who is the annuitant dies, this rider will terminate. 
 In the case of non-spousal joint owners where an owner who is not the
annuitant dies, the surviving owner (who is also the sole designated beneficiary) may elect to receive lifetime income payments under this rider instead of receiving any benefits applicable to the policy. The lifetime income payments must begin no
later than 1 year after the owner’s death and will be equal to the rider withdrawal amount divided by the number of payments made per year. Once the payments begin, no additional premium payments will be accepted and no additional withdrawals
will be paid. 
 ANNUITIZATION 
 On the maximum annuity
commencement date, as described in your policy, you will have the option to receive lifetime income payments that are no less than your rider withdrawal amount each year. This option will also guarantee that the sum of all income payments received
over time will equal or exceed the policy value on the maximum annuity commencement date. If the annuitant should die before the sum of all income payments received equals or exceeds the policy value on the maximum annuity commencement date, the
annuitant’s beneficiary will receive a final payment equal to the difference. 
 RIDER UPGRADE 

You may elect, in writing, to upgrade the withdrawal base to the policy value within [30] days after the [fifth] rider anniversary and every [fifth] rider
anniversary thereafter, subject to the issue age restrictions on the new rider. If an upgrade is selected, this rider will terminate and a new rider with the same features will be issued with a new rider date. The new rider will have its own growth
rate percentage and rider fee percentages which may not be the same as this rider’s percentages. 
 At the time upgrade, the rider withdrawal amount
will be recalculated based on the new withdrawal base. 
 The new rider date will be the date the Company receives all information necessary, at our Home
Office, in a written form acceptable to the Company, to process the upgrade. 
 TERMINATION 

 

	This	rider will terminate upon the earliest of: 

  

	1)	the date the policy to which this rider is attached terminates; 

  

	2)	the date the policy to which this rider is attached is assigned or if the owner is changed without our approval; 

  

	3)	the date of the annuitant’s death; 

  

	4)	the date you elect to upgrade (as described in Article IV of this rider); 

  

	5)	the date you elect to receive annuity payments under your policy; and 

  

	6)	the date you notify us in writing of your intention to terminate this rider (this date must be within [30] days after the [fifth] rider anniversary and every [fifth] rider anniversary thereafter). 


Termination of the rider will result in the loss of all benefits provided by the rider. 

Signed for us at our home office. 
  

			
	



		






  

					
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 APPENDIX 

The quarterly fee is calculated as follows: 

Multiply (1) by (2) divided by (3) multiplied by (4) where: 
  

	1)	Withdrawal Base 

  

	2)	Sum of each designated allocation group rider fee percentage multiplied by the applicable designated allocation group value 

  

	3)	Total policy value 

  

	4)	Number of days in the rider quarter divided by the number of days within the applicable rider year 

 The fee
adjustment for additional premium payments and excess withdrawals is calculated as follows: 
 Multiply (1) by (2) divided by (3) multiplied
by (4) where: 
  

	1)	Withdrawal base change (i.e. withdrawal base after the transaction minus the withdrawal base before the transaction) 

  

	2)	Sum of each designated allocation group rider fee percentage multiplied by the applicable designated allocation group transaction amount 


 

	3)	Total transaction amount 

  

	4)	Number of days remaining in the rider quarter divided by the number of days within the applicable rider year 

  

	The	fee adjustment for fund transfers is calculated as follows: 

  

	Multiply	(1) by (2) divided by (3) multiplied by (4) where: 

  

	1)	Withdrawal base 

  

	2)	Sum of each designated allocation group rider fee percentage multiplied by the applicable designated allocation group transaction amount 


 

	3)	Total policy value 

  

	4)	Number of days remaining in the rider quarter divided by the number of days within the applicable rider year 


The following two examples use assumed fees and values listed in the table below. The assumed rider year is not a leap year. 

 

													
	 Designated

Allocation Group
	  	Fee	 	 	Initial
Policy Value	 	  	Additional Premium
Used in Example 2	 
	 Group A
	  	 	2.50	% 	 	$	50,000	  	  	$	5,000	  
	 Group B
	  	 	2.40	% 	 	$	30,000	  	  	$	3,000	  
	 Group C
	  	 	2.30	% 	 	$	20,000	  	  	$	2,000	  

 Example 1: Calculation at rider issue for first quarter fee assuming an initial withdrawal base of $100,000. 

= 100,000 * [(50,000*0.0250) + (30,000*0.0240) + (20,000*0.0230)] / 100,000 * (91/365) 

= 100,000 * (1,250 + 720 + 460) / 100,000 * (91/365) 

= 100,000 * 2,430/100,000 * (91/365) 

= 2,430 * (91/365) 
 = $605.84

 Example 2: Calculation for first quarter fee assuming initial withdrawal base from Example 1 above, plus adjustment for additional premium payment
of $10,000 made with 20 days remaining in the first rider quarter (invested as shown above). The withdrawal base change and total transaction amount equal $10,000. 

Fee adjustment as follows: 
 = 10,000 *
[(5,000*0.0250) + (3,000*0.0240) + (2,000*0.0230)] / 10,000 * (20/365) 
 = 10,000 * (125 + 72 + 46) / 10,000 * (20/365) 

= 10,000 * 243/10,000 * (20/365) 

= 243 * (20/365) 
 = $13.32 

Total fee assessed at end of first rider quarter (assuming no further rider fee adjustments): 

= 13.32 + 605.84 
 = $619.16 

  

					
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 The following three examples use assumed fees and values listed in the table below. The assumed rider year is not
a leap year. 
  

																	
	 Designated

Allocation Group
	  	Fee	 	 	Policy Value	 	  	Partial Withdrawal
Used in Example 4	 	  	Fund Transfer
Used in Example 5	 
	 Group A
	  	 	2.50	% 	 	$	49,000	  	  	$	-5,000	  	  	$	-5,000	  
	 Group B
	  	 	2.40	% 	 	$	29,000	  	  	$	-3,000	  	  	$	3,000	  
	 Group C
	  	 	2.30	% 	 	$	19,000	  	  	$	-2,000	  	  	$	2,000	  

 Example 3: Calculation for second quarter fee at beginning of second rider quarter, assuming withdrawal base of
$110,000 and policy value of $97,000 invested as above. 
 = 110,000 * [(49,000*0.0250) + (29,000*0.0240) + (19,000*0.0230)] / 97,000 *
(91/365) 
 = 110,000 * (1,225 + 696 + 437) / 97,000 * (91/365) 

= 110,000 * 2,358/97,000 * (91/365) 

= 2,674.02 * (91/365) 
 = $666.67

 Example 4: Calculation for second quarter fee assuming beginning values as in Example 3 above, plus adjustment for partial withdrawal of $10,000
taken with 40 days remaining in the second rider quarter. Assumes withdrawal percentage of 5%, policy value of $97,000 prior to the transaction and change in withdrawal base as follows: 

Rider Withdrawal Amount (RWA) = Withdrawal Base * Withdrawal Percentage = 110,000 * .05 = $5,500 

Excess Withdrawal = Difference between assumed withdrawal amount and RWA = 10,000 - 5,500 = $4,500 

Withdrawal Base Adjustment = Max (Excess Withdrawal, Excess Withdrawal * Withdrawal Base prior to withdrawal / Policy Value after RWA has been withdrawn but
before excess withdrawal) = Max [4,500, 4,500 * 110,000 / (97,000-5,500)] = Max (4,500, 5,409.84) = $5,409.84 
 Fee adjustment as follows: 

= -5,409.84 * [(5,000*0.0250) + (3,000*0.0240) + (2,000*0.0230)] / 10,000 * (40/365) 

= -5,409.84 * (125 + 72 + 46) / 10,000 * (40/365) 

= -5,409.84 * 243/10,000 * (40/365) 

= -131.46 * (40/365) 
 = $-14.41

 Total fee assessed at end of second rider quarter (assuming no further rider fee adjustments): 

= 666.67 - 14.41 
 = $652.26 

The new Withdrawal Base = $110,000 - $5,409.84 = $104,590.16 

Example 5: Calculation for fund transfer occurring during second quarter with 25 days remaining in the rider quarter, assuming beginning values as in
Example 3 and withdrawal adjustment as in Example 4 above. 
 Withdrawal Base = $104,590.16 and assumed policy value of $90,000. Fund transfer amount of
$5,000 as allocated in table above. 
 Fee adjustment as follows: 

= 104,590.16 * [(-5,000*0.0250) + (3,000*0.0240) + (2,000*0.0230)] / 90,000 * (25/365) 

= 104,590.16 * (-125 + 72 + 46) / 90,000 * (25/365) 

= 104,590.16 * -7/90,000 * (25/365) 

= -8.13 * (25/365) 
 = $-0.56 

Total fee assessed at end of second rider quarter (assuming no further rider fee adjustments): 

= 652.26 - 0.56 
 = $651.70 

  

					
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