April 22, 2014
RiverSource Life Insurance Company
829 Ameriprise Financial Center
Minneapolis, MN 55474
RE: RiverSource MVA Account
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RiverSource(R) AccessChoice Select Variable Annuity | | RiverSource(R) Signature Select Variable Annuity |
RiverSource(R) Builder Select Variable | | RiverSource(R) Signature One Variable Annuity |
RiverSource(R) Endeavor Select Variable Annuity | | RiverSource(R) Signature One Select Variable Annuity |
RiverSource(R) FlexChoice Variable Annuity | | Evergreen Essential(SM) Variable Annuity |
RiverSource(R) FlexChoice Select Variable Annuity | | Evergreen New Solutions Variable Annuity |
RiverSource(R) Galaxy Premier Variable Annuity | | Evergreen New Solutions Select Variable Annuity |
RiverSource(R) Innovations Variable Annuity | | Evergreen Pathways(SM) Variable Annuity |
RiverSource(R) Innovations Select Variable Annuity | | Evergreen Pathways(SM) Select Variable Annuity |
RiverSource(R) Innovations Classic Variable Annuity | | Evergreen Privilege(SM) Variable Annuity |
RiverSource(R) Innovations Classic Select Variable Annuity | | Wells Fargo Advantage(R) Variable Annuity |
RiverSource(R) New Solutions Variable Annuity | | Wells Fargo Advantage(R) Select Variable Annuity |
RiverSource(R) Pinnacle Variable Annuity | | Wells Fargo Advantage(R) Builder Variable Annuity |
RiverSource(R) Signature Variable Annuity | | Wells Fargo Advantage Choice(SM) Variable Annuity |
| | Wells Fargo Advantage Choice(SM) Select Variable Annuity |
Post-Effective Amendment No. 3 to the Registration Statement on Form S-3
File No. 333-139776
Ladies and Gentlemen:
I am familiar with the above-referenced Registration Statement on Form S-3 filed by RiverSource Life Insurance Company (the “Company”) with the Securities and Exchange Commission in connection with RiverSource Guarantee Period Account Interests offered in connection with the above-referenced variable annuity contracts (“Guarantee Period Account Interests”).
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 give the following opinion:
1. The Company is duly incorporated, validly existing and in good standing under applicable state law and is duly licensed or qualified to do business in each jurisdiction where it transacts business. The Company has all corporate powers required to carry on its business and to issue the Guarantee Period Account Interests.
2. The Guarantee Period Account Interests issued by the Company, when offered and sold in accordance with the prospectus contained in the Registration Statement and in compliance with applicable law, will be legally issued and represent binding obligations of the Company in accordance with their terms.
I hereby consent to the filing of this opinion as an exhibit to the Registration Statement.
Sincerely,
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/s/ Timothy D. Crawford | | |
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Timothy D. Crawford | | |
Assistant General Counsel and | | |
Assistant Secretary | | |