June 29, 2012

Mark Cowan
Office of Insurance Products
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E. (Mail Stop 5-6)
Washington, D.C. 20549

ATTN: Document Control - Edgar

RE: Post-Effective Amendment No.1 on Form N-4
RiverSource Life Insurance Co. of New York ("Company")
RiverSource of New York Variable Annuity Account (Registrant")
       File Nos. 333-179335/811-07623
       RiverSource RAVA 5 Advantage Variable Annuity
       RiverSource RAVA 5 Select Variable Annuity
       RiverSource RAVA 5 Access Variable Annuity
       (offered for contract applications signed on or after April 30, 2012)


Dear Mr. Cowan:

This letter is in response to Staff's written comments received on or about
June 19, 2012 for the above-referenced Post-Effective Amendment filed on or
about May 11, 2012. Comments and responses are outlined below.

COMMENT 1. General

     The supplement is dated May 11, 2012.  Please note that the supplement
should be dated close to the effectiveness date.

RESPONSE: Complied. The supplement date will be the same as the effective
date.

COMMENT 2. The "Optional Benefits" paragraph in the "Contract in
Brief."

     Please clarify in this section that the investment restriction is currently
limited to one approved investment option.

RESPONSE: Complied. The following sentence has been added:

          Currently, there is only one approved investment option, Columbia
          Variable Portfolio - Managed Volatility Fund.

COMMENT 3. "Charges - Optional Living Benefit Charges."

     Please define the term "minimum contract accumulation value."  The term is
also undefined in the section entitled "Expense Summary - Optional Living
Benefits."

RESPONSE:  The term "minimum contract accumulation value" is defined in the
"Accumulation Protector Benefit Rider" section as follows:

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     MINIMUM CONTRACT ACCUMULATION VALUE (MCAV): An amount calculated under the
     Accumulation Protector Benefit rider. The contract value will be increased
     to equal the MCAV on the Benefit Date if the contract value is less than
     the MCAV on the Benefit Date.

     Your initial MCAV is equal to your initial purchase payment. It is
     increased by the amount of any subsequent purchase payments received. It is
     reduced by any adjustments for partial surrenders made during the
     Waiting Period.

Since all defined terms are capitalized, we have capitalized the term "minimum
contract accumulation value" in the "Expense Summary - Optional Living Benefits"
section and revised section "Charges - Optional Living Benefit Charges" as shown
below (underlined):

     We deduct an annual charge for this optional feature only if you select it.
     If selected, we deduct an annual charge based on a fee of 1.30% of the
     greater of your contract value or the Minimum Contract Accumulation Value
     (as defined in the "Optional Living Benefits - Accumulation Protector
     Benefit Rider" section) on your contract anniversary.

COMMENT 4. We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to be certain
that they have provided all information investors require for an informed
decision.  Since the insurance company and its management are in possession of
all facts relating to the insurance company's disclosure, they are responsible
for the accuracy and adequacy of the disclosures they have made.

          Notwithstanding our comments, in the event the insurance company
requests acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such request,
acknowledging that

  -    should the Commission or the staff, acting pursuant to delegated
       authority, declare the filing effective, it does not foreclose the
       Commission from taking any action with respect to the filing;

  -    the action of the Commission or the staff, acting pursuant to
       delegated authority, in declaring the filing effective, does not
       relieve the insurance company from its full responsibility for the
       adequacy and accuracy of the disclosure in the filing; and

  -    the insurance company may not assert this action as defense in any
       proceeding initiated by the Commission or any person under the federal
       securities laws of the United States.

RESPONSE: Confirmed.

If you have any questions concerning this filing or responses to the comments,
please contact me at (612) 678-4177, or Boba Selimovic at (612) 671-7449.

Sincerely,

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

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