April 23, 2010

Office of Insurance Products
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-0504

ATTN: Document Control - EDGAR

RE:   RiverSource Life Insurance Company ("Registrant")
      Post-Effective Amendment No. 2
      File. No. 333-149953
      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 Guaranteed Term Annuity
         ("Variable Annuities")

Dear Commissioners:

Registrant is filing Post-Effective Amendment No. 2 to the Registration
Statement on Form S-1 ("Amendment No. 2") with respect to the Variable Annuities
listed above. This Amendment No. 2 reflects the undertaking of the Registrant to
update the Variable Annuity prospectus in compliance with Section 10(a)(3) of
the Securities Act of 1933, including updated financial information. In
Registrant's view, this Amendment No. 2 does not contain disclosure that would
render it ineligible to become effective and is comparable to filing a
post-effective amendment on Form N-4 pursuant to Rule 485(b).

Pursuant to Rule 429 under the Securities Act of 1933, the prospectus contained
or incorporated herein by reference also relates to and constitutes a
post-effective amendment to Registration Statement Nos. 033-28976 and
333-114888.

Pursuant to Rule 461 of the Securities Act of 1933, as amended, Registrant
respectfully requests acceleration of the effective date of this Amendment No. 2
to April 30, 2010 or as soon as practicable thereafter. On behalf of RiverSource
Distributors, Inc., the Principal Underwriter for the Account, we are forwarding
with this letter a request for acceleration of the effective date of this
Amendment No. 2.

If there is anything I can do to expedite review of the enclosed Amendment No.
2, or if you have any questions regarding this filing, please contact me at
(612) 671-2237 or Boba Selimovic at (612) 671-7449.

Sincerely,


/s/ Rodney J. Vessels
---------------------------------
Rodney J. Vessels
Assistant General Counsel and
Assistant Secretary