April 20, 2012

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. 1 on Form S-3
          File. No. 333-149951
          RiverSource(R) Group Variable Annuity Contract ("Variable Annuity")

Dear Mr. Cowan:

Registrant is filing Post-Effective Amendment No. 1 to the Registration
Statement on Form S-3 ("Amendment No. 3") with respect to the Variable Annuity
listed above. This Amendment No. 1 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. 1 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
herein also relates to and constitutes a post-effective amendment to
Registration Statement No. 33-48701.

Pursuant to Rule 461 of the Securities Act of 1933, as amended, Registrant
respectfully requests acceleration of the effective date of this Amendment No. 1
to April 26, 2012 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. 1.

If there is anything I can do to expedite review of the enclosed Amendment No.
1, or if you have any questions regarding this filing, please contact me at
(612) 678-4177 or Boba Selimovic at (612) 671-7449.

Sincerely,

/s/ Dixie Carroll
--------------------------------
    Dixie Carroll
    Assistant General Counsel and
    Assistant Secretary