November 22, 2010

U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

ATTN: Document Control - EDGAR

RE: RiverSource Life Insurance Co. of New York
       on behalf of RiverSource of New York Variable Annuity Account 2
    INITIAL REGISTRATION STATEMENT ON FORM N-4
    Amendment No.42
    INVESTMENT COMPANY ACT NO. 811-07511
       RiverSource(R) Retirement Select Variable Annuity

Dear Commissioners:

Pursuant to Rule 477 of the Securities Act of 1933, RiverSource of New York
Variable Annuity Account 2 ("Registrant") and RiverSource Life Insurance Co. of
New York ("the Company"), hereby request that the above registration statement
Amendment No. 42 filed on Form N-4 for the RiverSource Retirement Select
Variable Annuity, initially filed with the Securities and Exchange Commission on
Oct. 14, 2010(Accession Nos. 0000950123-10-093131) be withdrawn.

The Company and the Registrant are requesting withdrawal of the Registration
Statement for the Contracts because the Company has determined not to offer the
Contracts for sale. Therefore, the Company and the Registrant hereby request
that an order be issued granting their request for withdrawal of the
Registration Statement for the Contracts as soon as is practicable. No Contracts
were sold in connection with the Registration Statement.

If you have any questions and would like to discuss this matter further, please
call 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