Exhibit 1.A(3)(c)(i)
Commission Structure:

Commissions are payable on premiums paid up to the target premium only. No
commissions are paid on premium in excess of the target premium. Any time a new
coverage segment is created, premiums allocated to that segment will be
commissionable up to that segment's target premium. The commission rates as a
percent of target premium are given below.


              POLICY YEAR OF COVERAGE SEGMENT        COMMISSION RATE

                             1                             5%

                             2+                            0%


Annual trail commission rates as a percent of the net account value:


              POLICY YEAR                      TRAIL COMMISSION RATE

                 1 - 10                                1.00%

                11 - 20                                0.75%

                  21+                                  0.20%


Commission Chargeback:

In the event that a policy for which a commission has been paid is lapsed or
surrendered by the Policy Owner or has a reduction in the Stated Death Benefit
during the first three policy years or is returned for refund of premium during
the Free Look Period as described in the policy, reimbursement is required from
Selling Broker-Dealer as shown below.


      POLICY OR SEGMENT YEAR              COMMISSION CHARGEBACK

                   1              5% of first year premiums up to target

                   2              2.5% of first year premiums up to target

                   3              1.25% of first year premiums up to target

                   4+             0%



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