April 29, 2016
RiverSource Life Insurance Company
829 Ameriprise Financial Center
Minneapolis, MN 55474
| RE: | RiverSource Life Insurance Company (“Registrant”) |
Pre-Effective Amendment No.1 on Form S-3
File No. 333-210986
RiverSource® Retirement Advisor Advantage Plus Variable Annuity
RiverSource® Retirement Advisor Select Plus Variable Annuity
RiverSource® Retirement Advisor 4 Advantage Variable Annuity
RiverSource® Retirement Advisor 4 Select Variable Annuity
RiverSource® Retirement Advisor 4 Access Variable Annuity
RiverSource® RAVA 5 Advantage® Variable Annuity(offered prior to April 30, 2012)
RiverSource® RAVA 5 Select® Variable Annuity(offered prior to April 30, 2012)
RiverSource® RAVA 5 Access® Variable Annuity (offered prior to April 30, 2012)
RiverSource® RAVA 5 Advantage® Variable Annuity (offered on or after April 30, 2012, but prior to April 29, 2013)
RiverSource® RAVA 5 Select® Variable Annuity (offered on or after April 30, 2012, but prior to April 29, 2013)
RiverSource® RAVA 5 Access® Variable Annuity (offered on or after April 30, 2012, but prior to April 29, 2013)
RiverSource® RAVA 5 Advantage® Variable Annuity(offered on or after April 29, 2013)
RiverSource® RAVA 5 Select® Variable Annuity (offered on or after April 29, 2013)
RiverSource® RAVA 5 Access® Variable Annuity (offered on or after April 29, 2013)
RiverSource® Retirement Group Annuity Contract I
RiverSource® Retirement Group Annuity Contract II
RiverSource® Guaranteed Term Annuity
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 prospectuses 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,
/s/ Timothy D. Crawford |
| Timothy D. Crawford |
| Assistant General Counsel and Assistant Secretary |
