September 10, 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: Initial Registration Statement on Form N-6
    RiverSource of New York Account 8 ("Registrant")
    File Nos. 333-183262 and 811-05213
    RiverSource Variable Universal Life 5/RiverSource Variable
    Universal Life 5 - Estate Series (VUL 5/VUL 5 - ES)

Dear Mr. Cowan:

This letter is in response to Staff's comments received via facsimile
transmission on September 6, 2012 for the above-referenced Initial Registration
Statement filed on or about August 13, 2012. Comments and responses for the
filing are outlined below.

COMMENT 1.a. Please clarify supplementally whether there are any types of
guarantees of support agreements with third parties to support any of the
company's guarantees under the policy or whether the company will be primarily
responsible for paying out on any guarantees associated with the policy.

RESPONSE: This response confirms that there are no types of guarantees
of support agreements with third parties to support any of the company's
guarantees under the policy. The company will be responsible for paying out on
any guarantees associated with the policy.

COMMENT 1.b. Please note that if you qualify for and intend to rely upon the
exemption provided by Rule 12h-7 under the Securities Exchange Act of 1934, you
must include a statement to that effect in the prospectus. See Release No.
33-8996 (January 8, 2009).

RESPONSE: The company files all reports required under the Securities
Exchange Act of 1934 and intends to continue to file such reports. The company
does not intend to rely on the exemption provided by Rule 12h-7 under the
Securities Exchange Act of 1934.



COMMENT 2. Financial Statements, Exhibits, and Other Information

Financial statements, exhibits and other information not included in the
registration statement should be filed by pre-effective amendment.

RESPONSE: The company will file all financial statements, exhibits and other
information required by Form N-6 that was not included in the registration
statement by pre-effective amendment.

In addition to the comments listed above, the Staff has requested that we make
the following representations on behalf of the Registrant. In connection with
the Initial Registration Statement listed above, RiverSource Life Insurance Co.
of New York, (the "Company") on behalf of the Registrant, hereby acknowledges
the following:

      The disclosures in the filing are the responsibility of the Company and
      the Company is fully responsible for the adequacy and accuracy of the
      disclosures in this filing. The Company represents to the Commission that
      comments made by the Commission, or the staff acting pursuant to delegated
      authority, or changes to disclosure in response to staff comments in the
      filing reviewed by the staff, do not foreclose the Commission from taking
      any action with respect to the filing, and the Company represents that it
      will not assert this action as a defense in any proceeding initiated by
      the Commission or any person, under the federal securities laws of the
      United States.

If you have any questions concerning this filing, please contact me at (612)
678-4177.

Sincerely,

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